Privacy And Data Protection Enactment And Enforcement Timelines During COVID-19

During COVID-19, in certain areas of the law, we have seen significant flexibility from regulators and government agencies in how they are addressing typical approval processes and/or compliance requirements. In the context of privacy and cybersecurity regulations, largely, regulators are emphasizing that personal privacy and data security are important now more than ever. New information is being collected and used in new ways. Certain data security vulnerabilities may be more prevalent in this work-from-home environment.

The below summarizes the status of enactments, deadlines, and other public comments from regulators surrounding privacy and data security laws globally.

• California Consumer Privacy Act (CCPA). CCPA became effective January 1, 2020. While the regulations are still not yet final, the Attorney General is permitted to begin bringing enforcement actions on July 1, 2020. Despite urging from various coalitions and trade associations to delay