California Consumer Privacy Act

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On July 24, 2025, the California Privacy Protection Agency (“CPPA”) unanimously voted to adopt a package of Proposed Regulations for the California Consumer Privacy Act (“CCPA”), marking a significant development in California privacy law. These cover Automated Decision-making Technology (“ADMT”), mandatory Cybersecurity Audits, Risk Assessments, and clarifications for the CCPA’s applicability to Insurance Companies. The package will move into its final review stage before formal enactment, once filed with the California Office of Administrative Law.

CCPA Steering Toward Operational Compliance

This is a clear signal that privacy compliance expectations in California are trending toward a more operational phase. The new rules are designed to give Californians greater control over how their personal information is used while pushing businesses toward higher levels of transparency and accountability, especially when automated decision-making and high-risk data processing is involved. For companies, this is more than just a theoretical update – it’s a clarion call to ensure these requirements are built into day-to-day governance, technology and process design, and vendor management practices.Continue Reading California Privacy Protection Agency (CPPA) Finally Voted to Adopt Much Debated Update to CCPA Regulations: What Your Business Should Know

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On June 3, 2025, the California Senate unanimously passed Senate Bill 690 (SB 690), a bill that seeks to add a “commercial business purposes” exception to the California Invasion of Privacy Act (CIPA).

After multiple readings on the Senate floor, SB 690 passed as amended, and will now proceed to the California State Assembly. SB…

On May 19, 2025, the California Senate Appropriations Committee, which handles budgetary and financial matters, held a hearing on California Senate Bill 690 (SB 690).  The proposed bill would amend the California Invasion of Privacy Act (CIPA) by adding an exception to the statute which has the effect of permitting use of tracking technologies for…

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The California Privacy Protection Agency (“CPPA”) has made it abundantly clear: privacy compliance isn’t just about publishing the right disclosures – it’s about whether your systems actually work. On May 6, the agency fined Todd Snyder, Inc. $345,178 for failures that highlight a growing regulatory focus on execution of California Consumer Privacy Act (“CCPA”) compliance. The action sends a powerful message: even well-resourced companies are not insulated from enforcement if they don’t actively test and manage how privacy rights are honored in practice.

Not Just Tools – Working Tools

The action against Todd Snyder was rooted in executional failure. The company had a portal in place for consumer rights requests, but it wasn’t processing opt-out submissions – a failure that lasted for roughly 40 days, according to the CPPA. The cookie banner that should have enabled consumers to opt out of cookie tracking would disappear prematurely, preventing users from completing their requests.

The company further required users to verify their identity before opting out and requested sensitive personal information, such as a photograph of their driver’s license. The CPPA determined this was not only unnecessary, but a violation in itself. The allegations around improper verification reflect concerns raised in a CPPA Enforcement Advisory issued last year, which cautioned businesses against collecting excessive information from consumers asserting their privacy rights.Continue Reading CPPA Underscores That Businesses Own CCPA Compliance – Even When Privacy Management Tools Fail

At the end of May, 2022, the California Privacy Protection Agency (“Agency”) released a preliminary draft of proposed regulations for the California Privacy Rights Act (“CPRA”). The 66-page draft proposal only covers a few topics the Agency is seeking to cover. The issues covered in this draft of the regulations include data collection and processing…

While the United States largely hit the brakes as of March in the wake of the COVID-19 crisis, California Attorney General Xavier Becerra made clear his intentions to begin enforcement of the Act on July 1, 2020, as originally planned. This announcement came despite many organizations’ pleas to defer enforcement in order to relieve the…

Cross-posted from The Global Privacy Watch blog.

Attorney General Becerra’s office posted the long-awaited draft CCPA regulations a little before 2:00 pm (PST) October 10th. It was a bit of a curve ball, to be perfectly honest (considering the final swath of amendments to the CCPA are not even final until Governor Newsom signs them, or on October 13th). Tellingly, the California Administrative Procedure Act requires the California Department of Finance to approve “major regulations” (and they have 30 days to do that) prior to publication. Based on this, it would seem that these regulations were drafted prior to the amendments to the CCPA going through the legislature. This does not seem like an effective way to draft regulations, but hey, no one should tell the AG he shouldn’t jump the gun! They are now out there so, one reviews anyway.

Topping out at a modest 24 pages (the CCPA itself is 19 pages), the regulations are organized into seven articles. We’re directing our comments to the issues that pop out to us initially, and as always, we’ll post further observations as things progress.
Continue Reading And the Wait for CCPA Rules is Over …. Kind Of

Those interested in keeping up with the latest news impacting the California Consumer Privacy Act have been heavily focused on AB 25, and its potential to exclude employees from the scope of the CCPA. In a marathon late-night session, the California Senate Judiciary Committee weighed in July 11 on various bills—including AB 25. An while AB 25 was part of the Committee debate, that amendment may actually make the bill less useful than first intended. Additionally, another bill made it out of committee which has the potential of a far greater impact than anyone seems to be noticing.
Continue Reading CCPA Amendments: Again Employees and the Loyalty Program Change Nobody is Talking About

In just a few short months, on January 1, 2020, the California Consumer Privacy Act (CCPA) is set to go into effect, establishing new consumer privacy rights for California residents and imposing significant new duties and obligations on commercial businesses conducting business in the state of California. Consumer rights include the right to know what…

Senate Bill 561, which would have generated even greater compliance challenges and litigation risk for businesses, has been held in committee and placed on suspense. This development effectively prevents the bill from advancing for a vote and is a bit of CCPA good news for businesses. It also serves as a minor setback to consumer…