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California AG Issues Final Regulations Ahead of CCPA Enforcement Date

June 4, 2020
Data Privacy Advisory

Computer keyboardOn June 2, 2020 the California Attorney General announced that it submitted final regulations to support enforcement of the California Consumer Privacy Act of 2018 (CCPA). The final regulations were submitted to the California Office of Administrative Law, which has 30 working days – plus an additional 60 calendars day if needed under COVID Executive Order N-4-20 – to perform a procedural compliance review.

Although CCPA required the AG to issue final regulations by the end of March to allow a July 1, 2020 enforcement date, the AG announced that his office is "committed to enforcing it starting July 1." To make that happen, the AG requested an expedited 30-business day review by the California Office of Administrative Law (OAL). Once the OAL review is complete, final regulations will be filed with the California Secretary of State.

The final regulations do not deviate materially  from CCPA statutory language and guidance provided to date by the AG's office. Meaning, companies that have been preparing for CCPA using those guidelines may not need to make significant changes ahead of July 1, 2020 or a future enforcement date should the date get pushed beyond July.

Now is a good time to perform an audit of your privacy practices and operational processes to make sure you can support the rights that California residents now have in terms of controlling their personal data, including the right to know, the right to delete and the right to opt-out of the sale of personal information that businesses collect, as well as additional protections for minors.

For more information, please contact Charu Ganesh, Jeff Stefan or your Varnum attorney.

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