Businesses have been finalizing their plans to comply with the California Consumer Privacy Act of 2018 (CCPA) by January 1, 2020, when the law becomes operative, but the ultimate trajectory of California’s post-2020 privacy regime remains in flux. As we detailed last month, the California Privacy Rights and Enforcement Act (CPREA), a proposed ballot initiative introduced by Californians for Consumer Privacy (the nonprofit behind the original CCPA initiative in 2018), would amend and expand the CCPA if it obtains enough signatures to appear on the 2020 California ballot and is approved by voters. In November, the nonprofit filed an amended version of the initiative — renamed Initiative 19-0021A1, “The California Privacy Rights Act of 2020” (CPRA) — that narrows some of the CPREA’s obligations and expands others.
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