Third Proposed Revisions To The CCPA Regulations: New Illustrative Examples And Minor Changes

On October 12, 2020, the California Attorney General published a third set of proposed modifications to the regulations adopted pursuant to the California Consumer Privacy Act. This follows revisions proposed in February and March 2020 that were largely approved following review by the Office of Administrative Law. As a reminder, the CCPA is in effect and being enforced by both the California AG and the plaintiffs' bar.

Multiple revisions to the regulations are not surprising given the complex nature of the law, the many comments from various stakeholders on the various versions of the regulations, and evolving interpretations as the law is applied. More substantive revisions may be in store depending on the outcome of Proposition 24 (the California Privacy Rights Act or CPRA) in November. Indeed, these third proposed changes to the regulations may become moot since the time it will take for them to be finalized will likely extend well past when the CPRA would become