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On Friday, August 14, 2020, the California Office of Administrative Law (OAL) approved the California Office of the Attorney General’s (OAG) final CCPA regulations and filed them with the California Secretary of State (SOS). The regulations were immediately effective. Notably, the final text of the regulations submitted to the SOS was modified from the one filed with the OAL. The OAG published an Addendum to the Final Statement of Reasons setting forth the changes. Many of the changes are stylistic and grammatical. However, some of the changes are substantive and will impact compliance efforts. The most notable changes are discussed below.
“There are only two types of companies: those that have been hacked, and those that will be.” When former FBI Director Robert Mueller spoke those words in 2012, he sounded hyperbolic. Almost a decade later, it seems prophetic.
In early June, the California Attorney General filed final CCPA regulations with the California Office of Administrative Law. The final regulations were accompanied by a 59-page Final Statement of Reasons along with six appendices containing over 500 pages of comments on the regulations and the Attorney General’s responses to those comments. One of the many topics that the Attorney General’s office discussed was the final regulation’s requirements for drafting privacy policies. Given that the drafting of a privacy policy is a necessary part of CCPA compliance, it is worth analyzing those comments.
More companies are doing more business online to survive the pandemic, and that’ll create even more data privacy concerns going forward. At the same time, new privacy regulations have taken hold, most notably the California Consumer Privacy Act. What are 5 steps to achieve compliance?
The CCPA has forced enterprises to rethink the types of personal information they collect and share, and the policies and procedures they implement to safeguard that data. Are enterprises prepared for the CCPA?
Studies and surveys consistently show that cybersecurity and data protection is one of the top five concerns of internal auditors, who worry that their organizations lack the internal resources to deal with security risks. On January 1, 2020, the California Consumer Privacy Act (CCPA) became effective, requiring new data privacy measures at most US organizations. Yet it is estimated that less than 10 percent are fully prepared for compliance with CCPA. Unfortunately, in this case, ignorance is not bliss and may result in hefty fines.
When California Governor Jerry Brown signed Senate Bill 327 on September 28, California became the first state to enact legislation expressly governing cybersecurity measures that must be employed by manufacturers of Internet-connected “smart” devices, collectively known as the Internet of Things (IoT). The law, to be codified at California Civil Code Sections 1798.91.04–06, became effective on January 1, 2020.
