By: David P. Saunders

On October 10, 2019, the California Attorney General surprised many by issuing 24 pages of proposed regulations implementing the California Consumer Privacy Act of 2018 (CCPA).  After reviewing the proposed regulations, they have left many in the industry shaking their heads.  Absent from the proposed regulations is much of the clarity that industry participants were hoping for.  In its place are additional obligations that not only risk confusing consumers, but that likely will pose administrative and logistical challenges.

Public comment on the proposed regulations is open through 5:00 pm PST on December 6, 2019.  Interested parties can submit comments by e-mail to [email protected] or by mailing comments to the Privacy Regulations Coordinator, California Office of the Attorney General, 300 South Spring Street, First Floor, Los Angeles, CA 90013.  Additionally, the Attorney General will be holding four public hearings on the new proposed regulations, the schedule of which is available here. 

In the meantime, let us examine the proposed regulations...

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