As Enforcement Looms, California Consumer Privacy Act Proposed Rules Gain Clarity Through New Modifications
On February 10, 2020, the Office of the California Attorney General issued proposed modifications to the proposed regulations implementing the California Consumer Privacy Act that were published on October 11, 2019. The proposed modifications clarify certain aspects of the initially proposed regulations and add detailed requirements related to some provisions of the CCPA. Among other things, the Modified Proposed Regulations set forth more clearly the responsibilities and liability exposure of service providers, pull back on some aspects of the proposed regulations to align with the CCPA’s express text, and offer relief for covered businesses from certain obligations the CCPA purports to impose but the fulfillment of which, in some circumstances, would be patently impracticable.
