In advance of International Data Privacy Day, California Attorney General Rob Bonta announced on January 27, 2023, that his office had initiated an “investigative sweep” of businesses that may not be complying with the California Consumer Privacy Act (CCPA). According to the announcement, the investigation is focused on 1) retail, travel, and food service apps that either do not honor consumer opt-out requests or do not provide the appropriate mechanisms for consumers to stop the sale of their data; and 2) businesses that fail to process consumer requests submitted via an authorized agent.
In light of AG Bonta’s announcement, companies doing business in California may want to re-assess whether they are subject to the CCPA, including the provisions of that law that have been amended by the California Privacy Rights Act (CPRA), and whether their policies and practices comply with the law. Indeed, with the CPRA having taken effect on January 1, 2023, covered businesses should understand that the scope of the CCPA is now much broader than before. For example, the CPRA gave consumers additional rights (e.g., the right to correct and the right to opt-out of sharing), removed exemptions for certain categories of personal information (e.g., business-to-business data and employment-related data), and imposed additional requirements on covered businesses.
The CPRA also created the California Privacy Protection Agency (CPPA), a new regulatory body dedicated exclusively to privacy regulation. The CPPA will have full administrative-enforcement authority over the CCPA as of July 1, 2023, and the agency has been actively engaged in rulemaking activity since its creation. Coincidentally, the CPPA published additional rulemaking materials last week and is likely to undertake significant enforcement efforts in the second half of this year. Now is therefore an opportune time for covered businesses to review their compliance efforts and prepare for any regulatory changes that may be coming.
Please contact Patrick Emerson McCormick, CIPP/US or another member of Lewis Roca’s Data Protection and Cybersecurity team for more information about the CCPA/CPRA and other state privacy and cybersecurity laws that may affect your organization.
Tags: Data Privacy and Cybersecurity- Of Counsel
John Gray is Of Counsel in Lewis Roca’s Litigation Practice Group and leads the firm’s Data Privacy and Cybersecurity Group. He is also a member of the firm’s AI Task Force.
As a litigator, John has more than a decade of experience in Arizona, California, and other forums across the ...
- Associate
Patrick is an associate in the firm's Litigation, Data Privacy and Cybersecurity, and eDiscovery Practice Groups. Patrick is a Certified Information Privacy Professional (CIPP/US) and assists clients on all aspects of data privacy and cybersecurity compliance and response, from ...
About This Blog
Lewis Roca is immersed in your industry and invested in your success. We share insights and trends that can affect your business.
Search
Topics
Archives
- September 2024
- August 2024
- May 2024
- March 2024
- February 2024
- September 2023
- April 2023
- March 2023
- February 2023
- December 2022
- November 2022
- October 2022
- September 2022
- July 2022
- June 2022
- May 2022
- April 2022
- March 2022
- February 2022
- January 2022
- December 2021
- November 2021
- October 2021
- September 2021
- August 2021
- July 2021
- June 2021
- May 2021
- February 2021
- January 2021
- December 2020
- October 2020
- September 2020
- August 2020
- July 2020
- June 2020
- May 2020
- April 2020
- March 2020
- February 2020
- January 2020
- December 2019
- November 2019
- October 2019
- September 2019
- August 2019
- July 2019
- June 2019
- May 2019
- April 2019
- March 2019
- November 2018
- April 2018
- February 2018
- January 2018
- December 2017
- November 2017
- September 2017
- August 2017
- June 2017
- May 2017
- April 2017
- March 2017
- November 2016
- October 2016
- September 2016
- August 2016
- April 2016
- January 2016
Authors
- Alfredo T. Alonso
- Amy E. Altshuler
- Edwin A. Barkel
- Trevor G. Bartel
- Nick Bauman
- G. Warren Bleeker
- Brooks Brennan
- Ogonna M. Brown
- Chad S. Caby
- John Carson
- Rob Charles
- Joshua T. Chu
- Howard E. Cole
- Katherine Costella
- Thomas J. Daly
- Pat Derdenger
- Thomas J. Dougherty
- Susan M. Freeman
- Yalda Godusi Arellano
- Salma G. Granich
- John C. Gray, CIPP/US
- Art Hasan
- Frances J. Haynes
- Dietrich C. Hoefner
- Jennifer K. Hostetler
- David A. Jackson
- Andrew Jacobsohn
- Kyle W. Kellar
- Kris J. Kostolansky
- Gregory S. Lampert
- Shaun P. Lee
- Glenn J. Light
- Laura A. Lo Bianco
- Karen Jurichko Lowell
- James M. Lyons
- H. William Mahaffey
- Constantine Marantidis
- A.J. Martinez
- Patrick Emerson McCormick, CIPP/US
- Michael J. McCue
- Lindsay L. McKae
- Linda M. Mitchell
- Gary J. Nelson
- Rachel A. Nicholas
- Laura Pasqualone
- Michael D. Plachy
- David A. Plumley
- Kurt S. Prange
- Katie M. (Derrig) Rios
- Robert F. Roos
- Karl F. Rutledge
- Daniel A. Salgado
- Mary Ellen Simonson
- Susan Strebel Sperber
- Jan A. Steinhour
- Ryan M. Swank
- Dustin R. Szakalski
- Chris A. Underwood
- Jennifer A. Van Kirk
- Hilary D. Wells
- Drew Wilson, CIPP/US
- Karen L. Witt
- Meng Zhong
Recent Posts
- The Importance of Retaining a Grandfathered Gaming Location in Nevada
- Welcome our 2024 Michael D. Nosler Scholarship Intern
- Going Viral: Navigating Promotional Sweepstakes Legality in the Social Media Era
- Arizona Voters Modify Creditors' Remedies with Passage of Proposition 209
- Nevada Gaming Control Board Issues Gaming Technology Approval Guidelines
- Amendments to Nevada Gaming Regulation 5
- Nevada Gaming Control Board Workshop on Public Regulation
- New Wave of Arizona Privacy Litigation Regarding Tracking Pixels
- Legal Issues, Problems, and Unanswered Questions Regarding a State’s Ability and Potential Departure from the Depository Institution Deregulation and Monetary Control Act of 1980 (“DIDMCA”)
- New Trademark Scam