California Privacy Rights Act

During its September 23, 2022 board meeting, the California Privacy Protection Agency (CPPA) provided an update on the status of the ongoing California Privacy Rights Act (CPRA) rulemaking.  Since the closure of the required 45-day comment period, the agency staff have been reviewing the written and oral comments submitted by the public.  The agency will be promulgating revised regulations, which will be drafted by the staff and presented to the Board.  These revisions will be followed by an additional public comment period of 15 to 45 days depending on the scope of the revisions.…

Continue Reading California Privacy Protection Agency Provides Update on CPRA Rulemaking

The California Privacy Protection Agency (“CPPA”) announced it will hold a special meeting on July 28, 2022 at 9 a.m. PST to discuss and potentially act on proposed federal privacy legislation, including the bipartisan American Data Protection and Privacy Act (“ADPPA”) (H.R. 8152).  The ADPPA is a comprehensive data privacy bill that advanced through…

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

In advance of the June 8, 2022 board meeting, the California Privacy Protection Agency (CPPA) staff has posted draft rules implementing the California Privacy Rights Act (CPRA).  The draft regulations keep much of the pre-existing California Consumer Privacy Act (CCPA) regulations intact, but modify certain provisions and propose new regulations.  A copy of the proposed…

As companies begin to prepare their CPRA compliance strategies, they are grappling with whether to include personal information processed in employment and business-to-business contexts. Currently, the CPRA’s partial exemptions for both of those types of data sunset on December 31, 2022. However, last week, the CA legislature introduced AB 2871 and AB 2891. AB…

Last week the California Privacy Protection Agency (“CPPA”) held its sixth Board meeting and first meeting of 2022.  The meeting notably included a discussion of the expected timing for issuing final regulations implementing the California Privacy Rights Act. …
Continue Reading California Privacy Protection Agency Clarifies Timing of Forthcoming CPRA Regulations

Last week, Virginia’s Joint Commission on Technology and Science held its second meeting of the Consumer Data Protection Work Group.

Instead of following a detailed rulemaking process for implementation like that provided for in the California Privacy Rights Act (CPRA), the Virginia Consumer Data Protection Act (VCDPA) is being reviewed over the next few months by a group of state officials, business representatives, and advocates. This group will publish recommendations by November 1, 2021, which the state legislature can consider if it amends the law before the VCDPA goes into effect on January 1, 2023. A stated goal of the group is to align the VCDPA with other privacy laws that states are enacting around the country.

At the meeting, the group heard public comments as well as a presentation by Deputy Attorney General Samuel Towell on behalf of the Office of the Attorney General of Virginia (OAG). The presentation covered issues that the OAG sees with the VCDPA’s implementation and proposed a number of recommendations for the group to consider: …
Continue Reading Virginia Consumer Data Protection Work Group Holds Second Meeting, Hears Recommendations from the Office of the Virginia Attorney General

Several states have proposed new privacy bills since their sessions began.  Some of the proposed bills carry over or re-introduce bills drafted in previous legislative sessions, while others are introducing first–in-time omnibus privacy bills.  In the high-level chart below, we compare five of the key state privacy frameworks: the CPRA, VCDPA (which we blogged about here), the NYPA, the general privacy provisions of the Washington Privacy Act, and the newly introduced Washington People’s Privacy Act (HB 1433). 
…
Continue Reading 2021 State Privacy Legislation Roundup: California, Virginia, New York, and Washington