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Cybersecurity Privacy Regulation Technology Media and Telecom

California’s Latest Privacy Rulemaking Proposes Further Obligations for Businesses  

While the the California Privacy Protection Agency kicked some of the more difficult issues down the road for further consideration, its first draft of proposed Regs is quite comprehensive with respect to the issues addressed. The authority for some of what is proposed is questionable and will likely be challenged in comments, if not judicial action, if such provisions become final.


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In May, the California Privacy Protection Agency (CPPA or Agency) released the first draft of its much-anticipated proposed California Privacy Rights Act of 2020 (CPRA) Regulations (Regs), as well as the Agency’s Initial Statement of Reasons. Although useful for the purpose of indicating what the Agency’s priorities may be, the draft Regs are far from complete. Of note, the Regs purposely omit provisions on key topics, including automated decision-making and profiling, cybersecurity audits, and risk assessments; consequently, companies should expect the Regs to expand far beyond their current 66-page length.

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