Written Comments Due by November 21
On November 3, 2022, the California Privacy Protection Agency (CPPA, or the Agency) issued modified proposed regulations implementing the California Privacy Rights Act (CPRA),1 which revise the initial proposed regulations released on July 8, 2022. The Agency’s Notice of Modifications to Text of Proposed Regulations triggers a 15-day public comment period, which ends on November 21, 2022. Below we identify the key takeaways from the changes made by the modified proposed regulations to the initial proposed regulations and discuss the potential topics to be covered in future regulations as discussed during the CPPA Board meeting held on October 28-29, 2022 (“the CPPA October Board Meeting”).
For a more in-depth analysis of the main components of the modified proposed regulations, please see our Data Advisor article.
The proposed regulations are subject to a mandatory 15-day public comment period. The CPPA will accept written comments until 8:00 a.m. PT on November 21, 2022. Comments may be submitted by the following means:
Comments may be submitted electronically to firstname.lastname@example.org by including "CPPA Public Comment" in the subject line and including the comment as an attachment to the email.
California Privacy Protection Agency
Attn: Brian Soublet
2101 Arena Blvd., Sacramento, CA 95834
We encourage businesses affected by the modified proposed regulations to submit comments to the CPPA. Wilson Sonsini Goodrich & Rosati routinely helps companies navigate complex privacy and data security issues, and will monitor CPPA guidance, enforcement, and litigation pursuant to the CPRA to assist clients with compliance. For more information or advice concerning your CPRA compliance efforts, please contact Tracy Shapiro, Eddie Holman, Clinton Oxford, Yeji Kim, or any member of the firm's privacy and cybersecurity practice.
The proposed regulations are referred to as “CCPA regulations” instead of “CPRA regulations.” This is because the CPRA was a ballot initiative that amended the CCPA; it did not create a separate, new law. To this end, the proposed regulations update the existing CCPA regulations and add new rules to implement and interpret the text of the CCPA, as amended by the CPRA. We refer to the latest version of the modified proposed CCPA regulations as the “modified proposed regulations” in this alert. Cited section references are to the modified proposed regulations unless otherwise stated.