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Alston & Bird Details 21 Potentially Significant Impacts from Draft CCPA Regulations

October 16, 2019 By Daniel Felz

 

Late last week, the Californa Attorney General published much-anticipated proposed Regulations under the California Consumer Privacy Act (“CCPA”). The Regulations are extensive and contain a number of potentially material business impacts.

To help companies work through the Regulations, Alston & Bird’s Privacy & Data Security team published a client advisory outlining “21 Potentially Significant Business Impacts” from the proposed CCPA Regulations. View the full advisory here.

This advisory tackles a number of issues likely of interest to companies attempting to get ready for CCPA, including:

  • Why posting a CCPA privacy policy on your website may not be enough to satisfy your CCPA notice obligations – instead you may need additional “just in time” notices at every specific point where you collect data (or lose the right to collect it);
  • Why you may hear discussions about a potential return of Do Not Track in the online context, this time as a “Do Not Sell My Info” request;
  • Why brick-and-mortar interactions with consumers may require companies to faciliatate “offline” CCPA rights requests; and
  • Why companies that take a position as vendor or service provider may need to examine any aspect of their business that involves pooling customer data for regulatory risk.

Alston & Bird is closely following the development of the CCPA and its Regulations. For more information, contact Jim Harvey, David Keating, Amy Mushahwar, Karen Sanzaro, or Daniel Felz.

Filed Under: California, Enforcement, Legislation, Online Privacy, Privacy, Regulation Tagged With: California Consumer Privacy Act (CCPA)

About Daniel Felz

Daniel Felz is a senior associate with Alston & Bird’s Privacy & Data Security Group. Dan leverages his extensive international experience to advise clients on global privacy, cybersecurity, technology, and adversarial matters.

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This blog is a service of Alston & Bird’s Privacy, Cyber & Data Strategy team and focuses on key data privacy and data security issues.


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