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Here Come the Proposed CCPA Regulations We’ve All Been Waiting For

After a long wait, the California Attorney General’s (AG) office held a news conference on October 10, 2019, and published proposed regulations implementing the California Consumer Privacy Act (CCPA). Companies gearing up for CCPA’s January 1, 2020, effective date should quickly review and assess the proposed regulations’ potential effects on their operations and consider attending upcoming public hearings or submitting public comments by December 6, 2019.

The AG’s rulemaking process has primarily focused on the issues on which the CCPA explicitly requires the AG to adopt implementing regulations. Thus, the newly proposed regulations cover:

  • Specific procedural requirements related to consumers’ requests to optout of the sale of their personal information;

  • The manner in which businesses are required to provide easily understandable notices (notice at collection, notice of the right to opt out of sale, and notice regarding financial incentive offerings) to consumers;

  • Rules governing a business’s response to consumer requests for information or requests for deletion, as well as mechanisms to verify the identity of individuals making requests;
    Additional requirements on obtaining parental authorization or valid consent from minors;

  • Additional restrictions on service providers’ processing of personal information; and

  • Specific recordkeeping requirements.

In conjunction with the public comment period, the AG has also announced four upcoming public hearings in major California cities. A copy of the schedule can be found here. Interested parties should take advantage of this opportunity and register in advance.

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About this Author

Laura Phillips, Drinker Biddle Law Firm, Washington DC, Communications Law Attorney
Partner

Laura H. Phillips is a partner in and chair of the firm's Government & Regulatory Affairs Practice Group and a member of the Telecommunications & Mass Media Team.  She has over 25 years of experience working in nearly every aspect of the telecommunications market.

Laura counsels wireless and wired technology entrepreneurs and represents these clients on issues related to the development of new technologies, including devoting substantive attention to the development of spectrum auctions, network...

202-842-8891
Peter A. Blenkinsop, Drinker Biddle Law Firm, Healthcare and Data Privacy Attorney, Washington DC
Partner

Peter A. Blenkinsop advises clients on data privacy, research compliance, and e-health. He co-chairs the firm’s Information Privacy, Security & Governance practice. Peter represents clients in the life sciences, health, nutrition, and technology sectors, among others.

Peter’s focus on data privacy and security law began well over a decade ago in the run up to implementation of the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). Since then, his practice has expanded well beyond health information privacy to data privacy and security generally. He advises companies on compliance issues raised by US federal and state privacy laws such as the Children’s Online Privacy Protection Act (“COPPA”), the CAN-SPAM Act, the Telephone Consumer Protection Act, and the Junk Fax Prevention Act. In this role, he assists clients in identifying privacy and security risks and developing information governance programs.

202-230-5142
Associate

Qiusi Y. Newcom assists clients with navigating emerging issues and regulatory compliance in telecommunications laws and international trade laws. She is an associate with the Telecommunications Team and the Customs and International Trade Team.

Prior to joining Drinker Biddle, Qiusi was an associate with a boutique employment law firm where she handled labor and employment matters before federal courts and federal agencies, including the Equal Employment Opportunity Commission. Qiusi also gained valuable litigation experience...

202-230-5370