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California Attorney General Shows No Sign of Slowing CCPA Rulemaking with Fourth Set of Proposed Modifications

By Mo Pham-Khan, Gregory P. Szewczyk & Philip N. Yannella on December 14, 2020
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The California Attorney General’s Office recently released a fourth set of proposed regulatory modifications to the California Consumer Privacy Act (the “CCPA”).

As background, the Attorney General’s Office had only just recently given notice of a third set of modifications on October 12, 2020.  The third set of modifications revised the regulations relating to the notice of a consumer’s right to opt-out of the sale of their personal information.  Our previous post detailed the specific changes in the third set of modifications.

The Attorney General’s Office received around 20 comments in response to the third set of modifications; these modifications have not yet been accepted and finalized.  The fourth set of modifications are in response to the comments to the third set of modifications and are intended to clarify and conform the proposed regulations to existing law.  The changes made include:

  • Revisions to section 999.306, subd. (b)(3), which clarifies that a business selling personal information collected from consumers in the course of interacting with them offline shall inform consumers of their right to opt out of the sale of their personal information by an offline method.
  • Proposed section 999.315, subd. (f), which reinstates the requirement for a uniform opt-out button to be used “in addition to . . . but not in lieu of . . . a ‘Do Not Sell My Personal Information link.”

The Attorney General’s Office is accepting written comments regarding the fourth set of proposed modifications until December 28, 2020.

The recently proposed modifications show that the Attorney General has no intention to slow the rollout of CCPA regulations after the recent voter approval of the California Privacy Rights Act (the “CPRA”), which further modifies and strengthens the existing protections in the CCPA.  Notably, the Attorney General is also allowed to issue regulations under the CPRA until that power is ultimately transferred to the newly created California Privacy Protection Agency.

Philip N. Yannella

yannellap@ballardspahr.com | 215.864.8180 | view full bio

As Practice Leader of Ballard Spahr’s Privacy and Data Security Group, and Practice Leader of the firm’s E-Discovery and Data Management Group, Philip N. Yannella provides clients with 360-degree advice on the transfer, storage, and use…

yannellap@ballardspahr.com | 215.864.8180 | view full bio

As Practice Leader of Ballard Spahr’s Privacy and Data Security Group, and Practice Leader of the firm’s E-Discovery and Data Management Group, Philip N. Yannella provides clients with 360-degree advice on the transfer, storage, and use of digital information.

Phil regularly advises clients on the Stored Communications Act (SCA), Computer Fraud and Abuse Act (CFAA), EU-US Privacy Shield, General Data Protection Regulation (GDPR), Defense of Trade Secrets Act, PCI-DSS, Telephone Consumer Protection Act (TCPA), New York Department of Financial Services Cybersecurity Regulations, ISO 27001 compliance, HIPAA Security Rules, and FTC enforcement activity, as well as eDiscovery issues—leveraging his experience serving as National Discovery Counsel for more than two dozen companies in nationwide litigation. He harnesses his deep knowledge of privacy, data security, and information governance laws to help multinational companies develop global information governance programs to comply with overlapping, and sometimes conflicting, laws. Phil serves on the advisory board for the ACC Foundation’s Cybersecurity Survey, the largest survey of in-house counsel on cybersecurity issues.

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  • Posted in:
    Privacy and Cybersecurity
  • Blog:
    CyberAdviser
  • Organization:
    Ballard Spahr LLP
  • Article: View Original Source

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