What Should We Do About The Draft CPRA Regulations?: Collection And Notice

The California Privacy Protection Agency (CPPA) recently released the draft proposed CCPA Regulations and draft initial statement of reasons. Importantly, these are draft regulations that are likely to be subject to extensive public comment and modification before they become final. At the June 8 meeting, the board moved to approve the draft regulatory text to begin the formal rule making process and public comment period.

These draft regulations redline the existing CCPA regulations. Though some provisions were largely unedited, they could be modified in forthcoming updates. This includes notices regarding financial incentives, rules for consumers under the age of 16, non-discrimination practices, and requirements for verifying requests. Requirements around cybersecurity audits, risk assessments, and automated decision-making technology were not covered in this draft.