The California attorney general (the AG) has concluded the first round of public comments on the proposed regulations that would serve to interpret and implement California’s sweeping new privacy law, the California Consumer Privacy Act (the CCPA).
After just under two months since the release of the proposed regulations (the Regs) by the AG and a series of four public hearings across the state in the past week, the final deadline to submit written comments in response to the Regs came and went on Friday, Dec. 6. Now that the first public comment period has ended, there will be revisions to the Regs followed by another wait period, which can be either 15 or 45 days, depending on the extent of changes in response to the first public comment period. In effect, this means that the Regs are subject to further changes, even post-Jan. 1, 2020.
This public comment period provided interested parties with the opportunity to submit written comments regarding the proposed CCPA Regs (set forth at §§ 999.300-999.341 of Title 11, Division 1, Chapter 20 of the California Code of Regulations). While many of our clients sought to convey their comments through their respective trade organizations, more than a dozen other clients asked us to supplement those efforts with a set of aggregate comments, which we filed and which are available here. A summary of our comments is below. Continue Reading