Client Alert: California Attorney General Releases Third Draft of Proposed CCPA Regulations

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Yesterday, California Attorney General Xavier Becerra released a third set of draft regulations (the New Modifications) implementing the California Consumer Privacy Act (CCPA).  The New Modifications incorporated comments provided after release of the Modified Draft Regulations on February 7, 2020 (February Draft Regulations).  The deadline to submit written comments to the New Modifications is March 27, 2020.  The final set of rules must be issued by July 1, 2020, the date enforcement of the CCPA is set to begin.

While there are fewer changes in the New Modifications than in the February Draft Regulations, these changes could still have a significant impact on your company’s CCPA compliance strategy.  Some of the key changes include:  

For assistance with your CCPA compliance program or privacy laws in general, please contact John Landolfi, Christopher Ingram, Christopher LaRocco, Sarah Boudouris, Gretchen Rutz, or your Vorys attorney.