This is the fifth in a series of articles about the implications of
the California Privacy Rights Act for employers.
The California Privacy Rights Act (CPRA), which goes into effect
January 1, 2023, will impose specific notice obligations on the
part of the employer. In a previous article, we covered the first type of
notice required under the CPRA, the notice at collection, which
explains how the employer will collect, use, and retain personal
information collected by the company. This article focuses on the
second type of notice required under the CPRA, which is a privacy
policy that must be posted online or on the employer's internet
website.
Employers familiar with the CPRA's predecessor, the
California Consumer Privacy Act (CCPA), likely know that the CCPA
exempts the data of employees, applicants, independent contractors,
dependents, and other individuals in their HR capacity
(collectively, "HR Individuals") from most of its
requirements. As such, other
