September 27, 2019
Stroock Special Bulletin
By: Quyen T. Truong, Stephen J. Newman
The activist behind the California Consumer Privacy Act (“CCPA”) is proposing a new ballot initiative to modify the statute and impose additional requirements on businesses. The CCPA was enacted in 2018 to head off a more stringent ballot initiative from Alastair Mactaggart, but the activist has announced that he plans to go directly to the voters for additional changes. His new proposal has a high chance of qualifying for the November 2020 ballot.
If approved by voters, the new ballot initiative would take effect on January 1, 2021, and would apply to all data collected on or after January 1, 2020. It would expand California’s privacy regime in the following ways, among others:
The ballot initiative would allow the legislature to adopt amendments by majority vote, but only to enhance privacy protections. Given the prospects and timing of the new ballot initiative, businesses will have to continue sprinting for compliance by January 1, 2020, with the amended CCPA requirements (and implementing regulations from the California Attorney General’s office to come at the turn of the year) — but be prepared for imposition of a still stricter framework in the year 2021.
The attorneys of Stroock’s Financial Services Litigation, Regulation and Enforcement Group are well positioned to answer your questions about California’s evolving privacy framework, as well as other privacy and cybersecurity issues.
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For More Information:
This article is for general information purposes only. It is not intended as legal advice, and you should not consider it as such.
September 27, 2019
Stroock Special Bulletin
By: Quyen T. Truong, Stephen J. Newman
The activist behind the California Consumer Privacy Act (“CCPA”) is proposing a new ballot initiative to modify the statute and impose additional requirements on businesses. The CCPA was enacted in 2018 to head off a more stringent ballot initiative from Alastair Mactaggart, but the activist has announced that he plans to go directly to the voters for additional changes. His new proposal has a high chance of qualifying for the November 2020 ballot.
If approved by voters, the new ballot initiative would take effect on January 1, 2021, and would apply to all data collected on or after January 1, 2020. It would expand California’s privacy regime in the following ways, among others:
The ballot initiative would allow the legislature to adopt amendments by majority vote, but only to enhance privacy protections. Given the prospects and timing of the new ballot initiative, businesses will have to continue sprinting for compliance by January 1, 2020, with the amended CCPA requirements (and implementing regulations from the California Attorney General’s office to come at the turn of the year) — but be prepared for imposition of a still stricter framework in the year 2021.
The attorneys of Stroock’s Financial Services Litigation, Regulation and Enforcement Group are well positioned to answer your questions about California’s evolving privacy framework, as well as other privacy and cybersecurity issues.
_______________________________________________
For More Information:
This article is for general information purposes only. It is not intended as legal advice, and you should not consider it as such.