On Friday, February 7, 2020, the California Attorney General
released an amended set of proposed regulations (as supplemented on
Monday, February 10, 2020, the "Revised Regulations")
implementing the California Consumer Privacy Act of 2018 (the
"CCPA"), including substantial changes to the draft
regulations issued in October.
While the Revised Regulations eliminate certain requirements
that businesses found to be onerous and provide clarification on
several points of lingering ambiguity, they also impose additional
new compliance obligations and still fail to address certain thorny
issues. Comments on the proposed regulations are due February 25,
2020.
This alert memorandum highlights certain notable changes that
may affect the mechanisms and procedures businesses must implement
in order to be in compliance with the CCPA, particularly with
respect to public privacy policies, other notices to consumers,
receipt and processing of CCPA consumer rights requests,
