California Attorney General Revises Proposed CCPA Regulations

On Friday, February 7, 2020, California’s Attorney General’s Office released revisions to the proposed regulations (the “Modified Draft Regulations”) for the California Consumer Privacy Act (“CCPA”). The CCPA is a first-in-the-nation comprehensive data privacy law that gives consumers rights to access and delete their personal information and to opt out of the sale of their personal information. The CCPA also requires businesses to make certain disclosures and operational changes regarding how they collect, use, and share personal information. The Modified Draft Regulations update the draft regulations originally proposed by the Attorney General in October 2019 (the “Original Draft Regulations”).

The Modified Draft Regulations contain important revisions to the Original Draft Regulations that clients should be aware of. We highlight some key provisions below. Among other changes, the Modified Draft Regulations:

  • Clarify the scope of the CCPA’s definition of “Personal Information.”
  • Provide guidelines for businesses to follow in making their disclaimers accessible to persons with disabilities.
  • Specify on what webpages the CCPA-required “Notice at Collection of Personal Information” must be displayed, and provide further guidance for mobile apps that collect a consumer’s personal information.
  • Provide a design for an “opt out” button for the “Do Not Sell My Info” link required by the CCPA.
  • Eliminate the 90-day [...]

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