Service providers often receive or access a customer’s personal information when performing contracted services. In the employment context, service providers may include payroll processors, Human Resource Information System (HRIS) or Applicant Tracking System (ATS) platforms, outsourced IT support, data storage, AI tool providers, or security services.

Under the EU and UK General Data Protection Regulations

In 2023, a California superior court halted enforcement of any final California Privacy Protection Agency regulation implemented until a period of 12 months from the date that individual regulations became final. Based on the ruling, enforcement of the initial regulations passed in March 2023 could not commence until March 2024.

The California Privacy Protection Agency

The European Union’s  General Data Protection Regulation (GDPR) is fast approaching and U.S. organizations that control or process personal data of EU residents are likely subject to these new data protection requirements.  Now is the time for U.S. employers to determine whether they are covered by the GDPR (see our blog post, Does the GDPR