California's new data privacy law - the California Consumer
Privacy Act of 2018 ("CCPA") - will go into effect on
January 1, 2020.
The CCPA obligations will affect applicable financial
institutions that navigated the implementation of the EU's
General Data Protection Regulation ("GDPR"). Many of the
systems and processes designed for GDPR compliance will satisfy the
CCPA requirements. Financial institutions should note that between
now and January 1, 2020, additional U.S. federal and state laws and
regulations on data protection may evolve and expand.
As explained more fully in a
Cadwalader memorandum, here are some key takeaways concerning
the CCPA:
- for U.S. businesses seeking to remain
outside the purview of the CCPA, the available
"carve-out" is narrow;
