On November 3, 2020, Californians voted to pass Proposition 24,
expanding and modifying the California Consumer Privacy Act
(“CCPA”), which came into force on January 1, 2020. The
new California Privacy Rights Act (“CPRA”) supersedes
the CCPA and will be operative on January 1, 2023 (with a look-back
period starting January 1, 2022). Until that time, the CCPA as
currently written remains in effect. As we learned during the lead
up to the CCPA, the time period to prepare for this type of
comprehensive and complex legislation passes quickly, and companies
need to begin their CPRA preparations sooner rather than later. In
this installment, we take a quick look at the current state of the
rulemaking activity for the CPRA.