On March 18, we filed a request to the California Attorney General, as part of the CCPA rulemaking process, seeking an additional six month delay in the enforcement of the CCPA to allow our clients time to better focus on business continuity and the safety of consumers and employees in response to the national COVID-19 state of emergency. CCPA enforcement is set to begin July 1, 2020, but the State of California has yet to even complete the rulemaking process for the implementing regulations.  The full filing is available here.

Photo of Gerald J. Ferguson Gerald J. Ferguson

Gerald Ferguson currently serves as the Intellectual Property, Technology and Media Group Coordinator for the firm’s New York office. Mr. Ferguson also serves as the national leader of the firm’s Privacy and Information Security group. He has worked with companies to create national…

Gerald Ferguson currently serves as the Intellectual Property, Technology and Media Group Coordinator for the firm’s New York office. Mr. Ferguson also serves as the national leader of the firm’s Privacy and Information Security group. He has worked with companies to create national and global privacy policies. He has extensive experience advising companies regarding compliance with state breach notification laws. Mr. Ferguson is able to advise clients regarding notification obligations quickly and efficiently using a state-by-state survey of the 47 jurisdictions with breach notification laws that is regularly updated by Baker Hostetler’s Privacy and Information Security group. As part of his proactive approach to an incident response, he works with forensic consultants to develop the substantive opinions necessary to support a determination that disclosure of a breach is not required when possible. If disclosure is required, he uses a team approach to carefully manage the process in a cost-effective and efficient manner that focuses on minimizing reputational harm.

Mr. Ferguson is Chairman of the Intellectual Property Committee of the New York State Bar Association, International Law and Practice Section.