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ARTICLE · 10 SEPTEMBER 2018

California Consumer Privacy Act – GDPR 2.0?

Mason Hayes & Curran LLP
Mason Hayes & Curran LLP
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Mason Hayes & Curran LLP

Mason Hayes & Curran LLP

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Shortly after the European Union's General Data Protection Regulation (GDPR) came into force in May 2018, California passed its own sweeping privacy legislation, the California Consumer Privacy Act of 2018 (CCPA).

United StatesPrivacy

Shortly after the European Union's General Data Protection Regulation (GDPR) came into force in May 2018, California passed its own sweeping privacy legislation, the California Consumer Privacy Act of 2018 (CCPA). So what are the key similarities and differences between the two laws?

Extraterritorial reach

Similar to GDPR's extraterritorial reach, the CCPA may apply to businesses without a physical presence in California. The GDPR applies to any business that offers goods or services to data subjects in the EU or monitors the behaviour of EU data subjects. In contrast, the CCPA applies more narrowly to entities that determine the purposes and means of processing personal information pertaining to California residents and meet one of three thresholds:

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