CPRA

The California Privacy Protection Agency (CPPA) Board, created by the California Privacy Rights Act (CPRA), has been busy of late. As we recently reported, the CCPA has hired renowned privacy technologist Ashka Soltani as its new Executive Director to lead the agency. Meanwhile, the agency’s committees have been hard at work. The Regulations Subcommittee has proposed its framework for its rulemaking process. Notably, the subcommittee recommends an immediate start to pre-rulemaking activities such as issuing an invitation for comments, the creation of additional subcommittees, and the identification of informational hearing topics. A pre-rulemaking process gives the agency flexibility to hear from stakeholders outside of the formal and constrained process that will begin once the regulatory process officially commences. The framework also notes that the notice of proposed rulemaking, initial statement of reasons (ISOR), and text of the regulations should be published in winter 2021-2022, with public hearings taking place thereafter. This suggests that stakeholders have a short window of opportunity to take advantage of the pre-regulatory educational period. It will be interesting to see if the agency conducts the kind of “listening tour” the Office of Attorney General (OAG) went on across the Golden State by means of town halls prior to its California Consumer Privacy Act (CCPA) rulemaking process, or elects to spend its time in more intimate and concerted explorations.
Continue Reading California Privacy Agency Moves Forward With Rulemaking Process

A little noticed provision of new consumer privacy laws in California and Virginia, effective January 2023, is the need for detailed data retention schedules and defensible destruction programs. Partner Alan Friel and Counsel Kyle Fath joined data management professionals on a recent panel at the International Association of Privacy Processional’s annual summit to explain these new requirements and how to prepare for them.  You can watch the recording for free here: Trim Costs, Reduce Risks and Improve Compliance: Data Retention the Right Way

Keep reading for tips on how to develop and implement a data retention program by Kyle Fath and Exterro’s Rebecca Perry.
Continue Reading Robust Data Retention Programs Required By New Laws

On Monday, May 4, 2020, Californians for Consumer Privacy – the organization behind the ballot initiative that was the genesis of the California Consumer Privacy Act of 2018 (CCPA) – announced that it is submitting signatures to qualify the California Privacy Rights Act (CPRA) for the November 2020 ballot. According to the announcement, “well over 900,000 signatures” will be submitted in counties across the state over the next several days.
Continue Reading CPRA Proponents Submit Over 900,000 Signatures for Ballot Initiative