The California Attorney General (AG) has issued the long-awaited draft regulations for the California Consumer Privacy Act (CCPA), which regulations will be officially filed on October 11, 2019. The AG stated that July 1, 2020 is the expected effective date of final regulations and enforcement. This is not to be interpreted as a safe harbor, but simply an enforcement delay. The public may submit written comments to the proposed regulations prior to December 6, 2019 at 5:00pm. The CCPA is effective on January 1, 2020.
Below are highlights of the key take-aways from the proposed regulations:
Disclosure. The regulations provide a clear emphasis on transparency and set forth format and content requirements for disclosures and privacy notices.
Requests. The regulations include additional parameters on the procedures for receiving and responding to consumer requests, including guidance on timing and reasonings for denying requests. The regulations also provide detailed guidance on how to verify the identity of a requesting consumer.
Training and Record Retention. The regulations reinforce and add guidance to the CCPA-specific training requirements and add new record retention requirements for consumer requests.
To learn more about whether the CCPA applies to your business and how McGrath North attorneys can assist in implementing an efficient and cost-effective compliance plan, contact McGrath North’s data privacy attorneys.