Record retention and records management policies are key elements for a company’s data protection program. Numerous recently enacted, or amended, data protection laws adopt data retention or storage limitation principles to safeguard personal information. Companies that do not have clearly defined record retention practices should take notice. Companies with existing practices should review those practices
California Consumer Privacy Act
CPRA Series: Sensitive Personal Information
The California Privacy Rights Act of 2020 (CPRA) becomes operative on January 1, 2023. Among its numerous amendments and additions to the existing California Consumer Privacy Act (CCPA), the CPRA expands the definition of Personal Information. Specifically, it adds the category of Sensitive Personal Information. This new category tracks the EU General Data Protection Regulation’s…
California DOJ Issues Fourth Set of Modifications to the CCPA Regulations
On December 10, 2020, the California Department of Justice (“Department”) announced a fourth set of modifications to the California Consumer Privacy Act’s (CCPA) regulations. The deadline to submit comments to the modifications is Monday, December 28, 2020.
As a quick recap of past developments related to the CCPA regulations, the Department first published proposed regulations…
As Voice Recognition Technology Market Surges, Organizations Face Privacy and Cybersecurity Concerns
A new report released by Global Market Insights, Inc. last month estimates that the global market valuation for voice recognition technology will reach approximately $7 billion by 2026, in main part due to the surge of AI and machine learning across a wide array of devices including smartphones, healthcare apps, banking apps and connected cars,…
CPRA Series: New, Expanded and Modified Consumer Rights
On November 3, 2020, Californians approved another significant piece of privacy rights legislation, the California Privacy Rights Act, or the CPRA. The CPRA amends and expands the already (almost) infamous CCPA (California Consumer Privacy Act), which is the privacy law that went into effect in the Golden State last year.
New Rights under CPRA
The…
CPRA Series: Impacts On Notice At Collection And Privacy Policy

Already at the cutting edge of U.S. privacy law, California jumped even further ahead of the pack with the recent approval by State voters of the California Privacy Rights Act (“CPRA”). The CPRA, which builds upon the already extensive framework of privacy rights and obligations established in the California Consumer Privacy Act (“CCPA”), is likely…
CPRA Series: Extension of CCPA’s Anti-Discrimination/Retaliation Provision to Employees, Applicants, and Independent Contractors
During the California Consumer Privacy Act’s (“CCPA”) amendment process prior to enactment, personal information in the employment context was highly contested and has continued to be a point of deliberation even after the CCPA’s effective date last January 1, 2020. CCPA excludes certain employment-related personal information from most of the act’s requirements until January 1,…
California Passes Prop 24: Here Comes CCPA 2.0
It goes without saying that November 3rd 2020 was an important day for the future of the nation, but it was also a significant day for the future of California privacy law. On Tuesday, a strong majority of California voters supported Proposition 24, a ballot measure which aims to expand and enhance the…
California DOJ Announces a Third Set of Modifications to the CCPA Regulations
Back in August, after much anticipation and several rounds of review and modification, the California Consumer Privacy Act (CCPA) regulations finally became effective. This was long awaited by businesses and their service providers looking for compliance guidance and clarity on key issues related to facilitation of consumer rights. This week, the California Department of Justice…
The CCPA’s “B2B” Exemption Is Also Extended by Governor Newsom
By signing AB 1281 into law on September 29th, 2020, California Governor Gavin Newsom amended the California Consumer Privacy Act (“CCPA”) to extend until January 1, 2022, not only the current exemption on employee personal information from most of the CCPA’s protections, but also the so-called “B2B” exemption. Welcomed by many “B2B” (business to business)…