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ARTICLE · 21 DECEMBER 2023

Updates To CCPA Proposed Regulations: Cybersecurity Audits

Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.
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The California Privacy Protection Agency ("CPPA") published a revised set of Draft Cybersecurity Audit Regulations ahead of the CPPA Board's December 8, 2023 meeting.

United StatesTechnology
Christopher Buontempo
Christopher Buontempo
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The California Privacy Protection Agency ("CPPA") published a revised set of Draft Cybersecurity Audit Regulations ahead of the CPPA Board's December 8, 2023 meeting. When the CPPA Board met on December 8, several key elements of the Draft Cybersecurity Audit Regulations, as outlined below, were discussed at length. The meeting also gave us valuable insight into how the CPPA Board perceives these requirements to apply to business – and what the audits may cost businesses.

Applicability Thresholds

The applicability thresholds in the draft cybersecurity audit regulations remains a hot button issue, and indeed were a key discussion point during both the September and December CPPA Board meetings. As a refresher, the draft regulations would require "every business whose processing of consumers' personal information presents significant risk to consumers' security...complete a cybersecurity audit."

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