The California Consumer Privacy Act (CCPA), touted as the toughest privacy act in the country, went into effect on July 1, 2020. Although the enforcement regulations have been tweaked three times during the last year, this week California Attorney General Xavier Becerra (AG) issued the final set of rules that his office will use to enforce the law.
According to the AG, the regulations were approved on August 14 after non-substantive changes were made by his office. Therefore, companies can use the final regulations to assist in determining their compliance with the law.
Although the AG has not yet publicly commenced an enforcement action under the law, the AG has stated that those efforts started on July 1. We anticipate that those efforts will be strategic and well thought out by the AG, as we have seen with the enforcement actions of other privacy laws. We believe that enforcement actions will be determined based upon the brands targeted, the substance of the violations, and where guidance can be the most impactful.
Now that the regulations are final, if they haven’t done so yet, companies may wish to review their compliance efforts with CCPA.