California Amends Its Consumer Privacy Act

On September 23, 2018, California Governor Jerry Brown signed into law SB-1121, a bill that makes several amendments to the Golden State's landmark Consumer Privacy Act ("CCPA"). California enacted the CCPA in June after legislators reached a last-minute compromise with a group of privacy activists who would have put a more stringent data protection measure on the November ballot. Given the hasty enactment of the law, we expected that the legislature would amend the CCPA before it becomes effective in 2020. SB-1121 is the first such amendment, and it makes several changes to the CCPA that businesses should be aware of.

1. Effective Date: The CCPA comes into effect on January 1, 2020 and SB-1121 does not change that, though it does add two caveats. First, it clarifies that the CCPA immediately preempts data privacy laws adopted by localities. Second, the new bill gives the Attorney General until July 1, 2020 to promulgate regulations for the CCPA, and delays