AG Releases Proposed CCPA Regulations

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October 16, 2019

Proposed CCPA Regulations

When the California Consumer Privacy Act (“CCPA”) was enacted in June 2018, it required the California State Attorney General to adopt regulations on or before July 1, 2020. On October 11, 2019, the widely anticipated draft CCPA regulations were released to the public. The intention of the proposed CCPA regulations is to provide clarity and specificity for purposes of guiding consumers and businesses through the CCPA implementation process.

What will the proposed CCPA regulations cover?

Outline of the Proposed CCPA Regulations

The California Legislature passed the CCPA in order to protect consumers’ privacy rights by imposing obligations on how businesses collect, use and share California State resident personal information. The proposed CCPA regulations provide guidance on several topics including, but not limited to:

  • The form, content and posting of notices that businesses are required to provide at or before the collection of personal information;
  • How to respond to requests to know, requests to delete and requests to opt-out;
  • The necessary disclosures that must be included in business privacy policies;
  • Special rules related to the collection of minors’ personal information; and
  • Clarification on who service providers are within the meaning of the statute and how service providers should handle CCPA consumer requests.

The Attorney General has also introduced new company-specific obligations as part of the draft regulations that were not included in the CCPA itself. In coming blogs, we will discuss this new language and how businesses should implement associated compliance measures.

Commenting on Proposed CCPA Regulations

The California Attorney General will hold four public hearings from December 2, 2019 to December 5, 2019, which will provide interested parties with the opportunity to present comments on the proposed CCPA regulations. Written comments are due on December 6, 2019. Public hearing locations can be found here.

As the effective date of January 1, 2020 rapidly approaches, we will continue to provide ongoing CCPA coverage in this blog. In future blogs, we will address how businesses should work to ensure CCPA compliance before the Attorney General begin enforcement on July 1, 2020. In the interim, if you are interested in learning more about this topic or require assistance in connection with consumer data privacy compliance for your business, please e-mail us at, or call us at (212) 246-0900.

The material contained herein is provided for informational purposes only and is not legal advice, nor is it a substitute for obtaining legal advice from an attorney. Each situation is unique, and you should not act or rely on any information contained herein without seeking the advice of an experienced attorney.

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Privacy Policies and the California Consumer Privacy Act (CCPA)

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David O. Klein

David O. Klein

David Klein is one of the most recognized attorneys in the telemarketing, technology, Internet marketing, sweepstakes and telecommunications fields. Skilled at counseling clients on a broad range of technology-related matters, David Klein has substantial experience in negotiating and drafting complex licensing, marketing and Internet agreements.

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