December 8, 2021

Volume XI, Number 342

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December 08, 2021

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December 07, 2021

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December 06, 2021

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California Bill Clarifies Timing for CPRA Rulemaking Authority

California recently passed AB 694, which makes a few “technical” changes to the California Privacy Rights Act (CPRA). Importantly, this amendment clarifies the timing for the new California Privacy Protection Agency’s (CPPA) rulemaking authority.

Previously, CPRA provided two different dates for when the Agency would assume responsibility for rule-making. One section said it was the earlier of July 1, 2021, or six months after the Agency provides notice to the Attorney General that it is prepared to begin rulemaking. However, a different section of the statute said it was the later of these two dates. Because the appointments to the CPPA were just made, the amendment clarifies that it is the later of these two dates – i.e., six months after notice to the Attorney General.

Putting it Into Practice: Though in the past, Companies now have clarity that CPPA’s rule-making authority was not in fact tied to July 1, 2021. Instead, the Agency’s authority will be tied to 6 months after it provides its notice of proposed rule-making (which we expect later this year/early 2022 as discussed here).

Copyright © 2021, Sheppard Mullin Richter & Hampton LLP.National Law Review, Volume XI, Number 281
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About this Author

Julia Kadish is an attorney in the Intellectual Property Practice Group in the firm's Chicago office.

Areas of Practice

Julia's practice focuses on data breach response and preparedness, reviewing clients' products and services for privacy implications, drafting online terms and conditions and privacy policies, and advising clients on cross-border data transfers and compliance with US and international privacy regulations and standards. She also workes on drafting and negotiating software licenses, data security exhibits, big data licenses, professional...

312.499.6334
Staff Attorney

Harrison Schafer is a staff attorney in the Intellectual Property practice group in the firm's Chicago office. He is a Privacy and Cybersecurity Fellow and a member of the Privacy and Cybersecurity Team. He is a certified information privacy professional (CIPP/E and CIPP/US) by the International Association of Privacy Professionals (IAPP).

Areas of Practice

As a fellow, Harrison’s practice focuses on publishing articles covering relevant legal developments in the privacy and cybersecurity space to...

312-499-6371
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