June 3, 2023

Volume XIII, Number 154


June 02, 2023

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May 31, 2023

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Updated CCPA Regulations Approved

Three months prior to the enforcement date of the California Consumer Privacy Act (CCPA), as amended, the California Office of Administrative Law approved the updated CCPA Regulations (final rulemaking documents will be posted here after processing). These updates take into account the CCPA’s expanded scope following its amendment by the California Privacy Rights Act of 2020 (CPRA), including new provisions regarding:

  • Consumer rights in relation to sharing, selling, and limiting the use of sensitive personal information;

  • Website and mobile app options in relation to “Do Not Sell or Share My Personal Information” requirements, user-enabled privacy controls, “alternative opt-out links,” and Global Privacy Control (GPC);

  • Dark patterns, notice, and transparency considerations; and

  • Service provider, contractor, and third-party contract requirements.

Although these regulations provide clarity on many of the changes the CPRA brought about, there remain several issues the California Privacy Protection Agency (CPPA) needs to address in its next round of regulations, including cybersecurity audits, risk assessments, and automated decision-making. The preliminary comment period for the next round of regulations ended on March 27, 2023. Initial draft rules on these topics may be released later this year.

©2023 Greenberg Traurig, LLP. All rights reserved. National Law Review, Volume XIII, Number 89

About this Author

Zachary S. Schapiro Attorney Greenberg Traurig San Francisco CA

Zachary S. Schapiro is an associate in the Data Privacy & Cybersecurity Practice in Greenberg Traurig’s San Francisco office. He assists clients with their privacy and data security compliance issues under regulatory regimes, particularly in the EU and United States. Zachary has experience drafting and negotiating data processing agreements, including those involving international data transfers. He also advises clients on their privacy policies and terms of use.

Gretchen A. Ramos, Lawyer, Greenberg Traurig, Data, Privacy & Cybersecurity,The Cloud,Artificial Intelligence, Big Data

Gretchen A. Ramos is Co-Chair of the Data, Privacy & Cybersecurity Practice and focuses her practice on privacy, cybersecurity, and information management. A creative problem-solver with a long track record of success in commercial disputes, she never loses sight of the simple fact that she works in a service industry. Clients appreciate not only her legal skills, but also her direct, no-nonsense approach to client service, including her bullet-pointed emails, snapshot executive summaries, and creativity in finding ways to streamline communications for in-house counsel with dozens of...