Opportunity To Influence Rulemaking Under The California Privacy Rights Act

In a recently issued invitation for preliminary comments, the California Privacy Protection Agency (Agency) has solicited input on issues it should address in upcoming rulemaking pursuant to the California Privacy Rights Act of 2020 (CPRA). The Agency, which was established by the CPRA (adopted by state ballot initiative in November 2020), is tasked with implementing and enforcing the California Privacy Protection Act (CCPA), as amended by the CPRA. The Agency's invitation is an important opportunity for businesses regulated by the CCPA—which includes any business with more than $25 million in annual revenue that collects personal information from at least one California resident—as well as privacy advocates, to stake out a position on the regulatory framework that will govern interpretation and enforcement of the amended CCPA.