California Privacy Rights Act Passes - Dramatically Altering The CCPA

Voters in California have passed Proposition 24, commonly referred to as the California Privacy Rights Act of 2020 (“CPRA”).  Less than a year after the CCPA became effective, the voters' approval of the CPRA will provide significant new rights to California consumers, create new compliance obligations for covered businesses, establish a new enforcement agency, and provide for data minimization and retention obligations, among other aspects.  Below, we provide an overview of certain important aspects. 

1. How Long Before the CPRA Becomes Effective? 

The CPRA becomes effective January 1, 2023.  Provisions that apply to covered business collection of personal information will apply to personal information collected on or after January 1, 2022.  However, the exceptions for certain business-to-business activity and employees were extended by the CPRA immediately upon it passing to January 1, 2023.  As it stands, both of these exceptions will end when the CPRA