SB-1121 Does Not Fix The CA Consumer Privacy Act, But Would Delay Enforcement

In response to controversies concerning consumers' personal information, such as the Facebook/Cambridge Analytica controversy, and a California ballot initiative that qualified for the November ballot and proposed the California Consumer Privacy Act ("CCPA Initiative"), the legislature in California responded with AB-375, which proposed an alternative version of the California Consumer Privacy Act of 2018. The authors of AB-375 worked out a compromise with the sponsors of the CCPA Initiative, and AB-375 was passed and signed by Governor Jerry Brown, becoming the California Consumer Privacy Act of 2018, codified at Title 18.1.5 of the California Civil Code (the "CCPA"). We have written about the CCPA here and here. The CCPA becomes effective January 1, 2020, though practically, businesses will need to start data mapping and recordkeeping on January 1, 2019, to be able to be in compliance upon the effective date. The legislature has already started a process of