California Consumer Privacy Act Update: Assembly Approves 12 Amendments - Changes Would Exclude Employees And Vehicle Information, Protect Loyalty Programs

Ashley Shively is a Partner in Holland & Knight's San Francisco office

HIGHLIGHTS:

• California's protracted legislative and regulatory process has complicated the landscape for businesses needing to implement the operational, technical and procedural changes required by the California Consumer Privacy Act.
• California lawmakers introduced a series of bills in 2019 to clarify and refine the scope of the Act prior to the effective date of Jan. 1, 2020. One notable proposal to expand the private right of action was blocked during the legislative process. A number of other bills have passed the California Assembly and now are being considered in the Senate.
• Industry has supported the need to remove certain categories of data, namely employees and contractors, from the scope of the law, as well as the need to protect businesses' disparate treatment of consumers who are part of loyalty programs. Whether those bills will be signed into law, however, may not be