More Proposed CCPA Regulations, but Without Significant Changes
The California Attorney General (“AG”) proposed changes to the California Consumer Privacy Act (“CCPA”) regulations on October 12, 2020. Many of the proposed changes align with provisions that the AG withdrew over the summer during the California Office of Administrative Law (“OAL”) approval process. Although most businesses likely won’t need to materially alter current business practices if the changes are accepted, some adjustments may be required in specific situations. The proposed changes address the following topics:
the requirements relating to providing a notice of the right to opt-out to offline consumers;
the need for the opt-out of sale process to be easy and to not impair the opt-out process;
what proof a business can request from an authorized agent and a consumer when a consumer makes an individual rights request through an authorized agent; and
additional privacy notice requirements for certain circumstances when businesses process personal information of minors under the age of 16.
The proposed regulations are now in a 15-day public comment period, which will end at 5pm PST on October 28, 2020.