July 5, 2020

Volume X, Number 187

July 03, 2020

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California AG Issues Final Regulations Ahead of CCPA Enforcement Date

On June 2, 2020 the California Attorney General announced that it submitted final regulations to support enforcement of the California Consumer Privacy Act of 2018 (CCPA). The final regulations were submitted to the California Office of Administrative Law, which has 30 working days – plus an additional 60 calendars day if needed under COVID Executive Order N-4-20 – to perform a procedural compliance review.

Although CCPA required the AG to issue final regulations by the end of March to allow a July 1, 2020 enforcement date, the AG announced that his office is "committed to enforcing it starting July 1." To make that happen, the AG requested an expedited 30-business day review by the California Office of Administrative Law (OAL). Once the OAL review is complete, final regulations will be filed with the California Secretary of State.

The final regulations do not deviate materially  from CCPA statutory language and guidance provided to date by the AG's office. Meaning, companies that have been preparing for CCPA using those guidelines may not need to make significant changes ahead of July 1, 2020 or a future enforcement date should the date get pushed beyond July.

Now is a good time to perform an audit of your privacy practices and operational processes to make sure you can support the rights that California residents now have in terms of controlling their personal data, including the right to know, the right to delete and the right to opt-out of the sale of personal information that businesses collect, as well as additional protections for minors.

© 2020 Varnum LLPNational Law Review, Volume X, Number 156


About this Author

Susan Benington Corporate Attorney Varnum Law Firm

Susan is a corporate attorney who focuses her practice on data security and privacy matters. She is experienced in negotiating privacy terms for commercial technology and data licensing agreements, and drafting complex consumer privacy notices and disclosures. She has substantial experience counseling global business and technology clients on data privacy obligations and risks relating to connected products and services. She is skilled at guiding clients through global and domestic privacy compliance efforts, such as GDPR and CCPA.

Susan previously served as data privacy and...

Jeffrey M. Stefan II Auto and Emerging Technology Attorney Varnum Law Firm

Jeffrey is a technology-focused corporate attorney with broad legal authority in autonomous and connected vehicles. He previously served as autonomous vehicle counsel for a major global automaker providing regulatory counsel and transactional support. Prior to that role, he supported the automaker's emerging technology portfolio, which included connected vehicle services and other advanced safety technologies.

Jeffrey helps his clients navigate the evolving legal and public policy landscape for new and emerging technologies. He additionally focuses on technology startups assisting them through every stage of their development. Jeffrey is also credentialed as an IAPP Certified Information Privacy Professional and his practice covers an array of privacy matters.

In addition to his emerging technology practice, Jeffrey handles a wide range of corporate transactions including mergers and acquisitions, supply chain agreements and other commercial and real estate transactions.

Charumati Ganesh Data Privacy Attorney Varnum

Charu holds a CIPP/US certification and focuses her legal practice on Data Privacy and Cybersecurity. Charu represents clients in a number of industries, including autonomous and connected vehicles and the consumer data marketplace. Charu is able to skillfully navigate the intricacies of the rapidly-evolving data privacy and cybersecurity regulatory landscape and help her clients develop policies and procedures that comply with both international and domestic privacy laws.

Charu has represented clients in the insurance, manufacturing and agricultural industries through regulatory...