Privacy Alert: Final Proposed Regulations Filed for CCPA

On June 1, California Attorney General Xavier Becerra submitted the final proposed regulations to the California Consumer Privacy Act (CCPA) to the California Office of Administrative Law (OAL). These final regulations are substantially unmodified from the regulations issued for review in March.

Typically, the OAL has 30 days to review and approve regulations, extended an additional 60 days by Executive Order N-40-20 due to the COVID-19 pandemic. Once the OAL approves the regulations, the final regulations are filed with the Secretary of State and become enforceable. Here, however, the Attorney General’s Office requested an expedited review (asking that the OAL complete its review within 30 business days) to finalize the proposed regulations for the CCPA.

It is uncertain whether the regulations will be finalized within the next 30 days, but enforcement of the CCPA is still set to begin July 1, 2020.

For assistance with your CCPA compliance program or privacy laws in general, please contact John Landolfi, Christopher Ingram, Christopher LaRocco, Sarah Boudouris, Gretchen Rutz, or your Vorys attorney.