At the Intersection of Technology, Law, and Business
October 15, 2020 - Privacy + Data Security

October Surprise: California DOJ Proposes Additional Modifications to CCPA’s Implementing Regulations

Recent Decision Compelling Disclosure of Data Breach Incident Response Report Highlights the Importance of Preserving Privilege and Protecting Work Product

Just two months after the final implementing regulations under the California Consumer Privacy Act of 2018 (CCPA) (“the Regulations”) were approved and took effect, California’s Department of Justice (DOJ) has issued another set of proposed modifications and invited written comments from interested stakeholders.  

The modifications, which re-introduce provisions that California’s Office of Administrative Law (OAL) withdrew before finalizing the Regulations in August 2020, could impact covered businesses’ CCPA compliance programs, particularly with respect to their provision of notices regarding consumers’ right to opt out of the sale of their personal information, as well as the submission of consumers’ opt-out requests. Please read our summary of the proposed modifications.

Read our client alert.