On Wednesday, March 11, 2020, the California Attorney General released a second set of modifications (the “March Revisions”) to the proposed regulations implementing the California Consumer Privacy Act of 2018 (the “CCPA”), including substantive changes to both the initial draft regulations issued in October (the “Initial Regulations”) and the revisions published Friday, February 7, 2020 (as supplemented on Monday, February 10, 2020, the “February Revisions”).
(We previously analyzed the CCPA here, the legislative amendments here, the Initial Regulations here, and the February Revisions here.) While the March Revisions address several of the issues raised by stakeholders commenting upon the February Revisions, there are many issues that remain unaddressed. Another round of modifications to the regulations may be issued following the conclusion of the public comment period on March 27, 2020.
This alert memorandum highlights certain notable changes to the proposed regulations, particularly with respect to service providers, requirements for privacy policies and other notices to consumers, and the processing of CCPA consumer rights requests.
Please click here to read the full alert memorandum.