August 31, 2023

California Privacy Enforcement: No Rest for the Regulated

Privacy law compliance dates remain on the horizon for California employers. Provided below are a few key updates:

California’s Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA)):

As discussed here, a last-minute ruling on July 3, 2023, by a County of Sacramento Superior Court, stayed enforcement of employer related CCPA regulations[i] until March 29, 2024. In response, on July 14, 2023, California Attorney General Rob Bona announced his office would initiate an investigative sweep – through inquiry letters sent to large California employers – requesting information on businesses compliance efforts under the CCPA.

That same day, the California Privacy Protection Agency (Agency) held a board meeting reinforcing Agency mandates to continue enforcing existing CCPA regulations effective as of January 1, 2023 (e.g., privacy policies, right to delete and consumer requests fulfillment/procedures).

California employers subject to the CCPA/CPRA should continue working toward compliance as the March 29, 2024 date is just around the corner. This is important as the Agency has also had time to marshal its regulatory enforcement assets which it will be ready to launch on March 29th.

For information on enforcement updates and compliance-related resources check out the Agency’s Consumer Complaint Portal. The Portal also contains useful links to FAQs and important announcements.


[i] The “California Privacy Rights Act of 2020” (“CPRA”), amended the California Consumer Privacy Act of 2018 (“CCPA”); it did not create a separate, new law. Because the regulations implement and interpret the language in the text of the CCPA, as amended by the CPRA, they are referred to generally as the CCPA regulations.