California Consumer Privacy Act (CCPA)

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On August 24, 2022, the California Office of Attorney General (OAG) published a summary of 13 CCPA investigations, “illustrative” of situations in which notices of alleged noncompliance were sent and remedial measures were implemented.  Note that the CCPA’s mandatory notice-and-cure period will expire on January 1, 2023.  Following that, the California Privacy Protection Agency will have the discretion to grant cure periods.…

Continue Reading California’s Office of the Attorney General Posts 13 New CCPA Investigations

Today, the California Attorney General announced the first settlement agreement under the California Consumer Privacy Act (“CCPA”).  The Attorney General alleged that online retailer Sephora, Inc. failed to disclose to consumers that it was selling their information and failed to process user requests to opt out of sale via user-enabled global privacy controls.  The Attorney General also alleged that Sephora did not cure these violations within the cure period. …

Continue Reading California Attorney General Announces First CCPA Settlement

During its June 8, 2022 board meeting, the California Privacy Protection Agency (CPPA) voted to initiate the formal California Privacy Rights Act (CPRA) rulemaking process.  The draft rules are expected to be very similar to those previously published in advance of the Board meeting, although Deputy Attorney General Lisa Kim noted during the meeting that minor errors may be updated prior to the formal submission of the draft rules.  The current draft rules and Initial Statement of Reasons (ISOR) continue to be accessible on the CPPA website.…

Continue Reading California Privacy Protection Agency Votes To Initiate Formal Rulemaking Process

The California Privacy Protection Agency (“CPPA”) held two informational hearings on March 29, 2022 and March 30, 2022, in anticipation of its upcoming rulemaking later this year.  While the CPPA Board was present throughout the hearings, its members did not present any views as part of the program.  The speakers covered the following topics of note:…
Continue Reading California Privacy Protection Agency Holds Informational Hearings

Earlier this month the California Privacy Protection Agency (CPPA) held its inaugural public meeting.  The CPPA was created under Proposition 24, the California Privacy Rights Act (CPRA), which was approved by California voters on November 3, 2020.
Continue Reading California Privacy Protection Agency Holds First Meeting, Preparing for Upcoming Rulemaking

The five members of the California Privacy Protection Agency (“CPPA”) were announced today.  The members – who were appointed by Governor Newsom, Attorney General Becerra, Senate President pro Tempore Atkins, and Assembly Speaker Rendon – will lead the new agency, which will have rulemaking and enforcement authority under the California Privacy Rights Act (“CPRA”).
Continue Reading Members of the California Privacy Protection Agency Announced

Last week, a federal district court in San Francisco dismissed a claim under the California Consumer Privacy Act (“CCPA”).  The plaintiff alleged that Google had collected personal information without complying with the CCPA’s notice and consent requirements.  The court held that the CCPA’s private right of action does not extend to these provisions of the law.  It appears that this is the first time a court expressly reached this conclusion.  The case is McCoy v. Alphabet, No. 20‑cv‑05427 (N.D. Cal. Feb. 2, 2021).

For context, the plaintiff alleged that Google used an internal program called “Android Lockbox” on its Android operating system to monitor and collect data from Android users as they used non-Google apps on their phones.  The alleged data collection included when and how often these third-party apps were used and the amount of time users spent on the third-party apps.  Based on these allegations, the plaintiff asserted eleven different claims.  Among these was a claim that Google violated the CCPA by failing to comply with the law’s requirements related to notice and consent.
Continue Reading Court Dismisses CCPA Claim Against Google