January 28, 2022

Volume XII, Number 28

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OAG Proposes Additional Changes to CCPA Regulations

Today, the California Office of the Attorney General (OAG) released a second set of modifications to its proposed California Consumer Privacy Act (CCPA) Regulations.

The proposed regulations were first published and noticed for public comment on October 11, 2019. On February 10, 2020, the OAG released modifications to the proposed regulations based on the earlier comments it received. The current, second set of modifications to the proposed regulations are in response to the comments the OAG received in February.

Notably, the current draft of the proposed regulations strikes section 999.302, which purported to provide “guidance regarding the interpretation of CCPA definitions” through an example of when IP addresses may not qualify as “personal information,” as discussed in GT’s February 11 summary, OAG Proposes Significant Changes to CCPA Regulations.

The current draft likewise removes the previous version’s suggested images for an “opt-out button or logo” found in section 999.306(f).

The OAG will accept written comments until Friday, March 27, 2020, at 5:00 p.m. PST.

©2022 Greenberg Traurig, LLP. All rights reserved. National Law Review, Volume X, Number 72
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About this Author

Darren Abernethy Data Privacy Attorney Greenberg Traurig San Francisco
Of Counsel

Darren J. Abernethy is a data privacy attorney with more than a decade of experience, including in private practice in Washington, D.C. and as in-house counsel at startups and a leading privacy technology vendor. He advises clients on matters related to advertising technology, privacy and data governance, and FTC best practices.

Darren focuses on the California Consumer Privacy Act (CCPA), the European Union General Data Protection Regulation (GDPR)/ePrivacy, digital advertising, direct marketing, and product counseling.

415-655-1261
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