On March 11, 2020, California’s Office of the Attorney General proposed a second set of revisions to the draft California Consumer Privacy Act (CCPA) regulations. These proposed regulations were first published on October 11, 2019, and summarized in our previous Alert. The most recent changes come on the heels of modifications to the regulations released on February 10, 2020, which were summarized in this Alert.
The deadline for providing comments to the second set of modified proposed regulations is March 27, 2020.
Overall, most of the changes were of a technical nature and not substantive. This Alert highlights the notable changes.
Removal of Definitional Guidance Section
The section titled “Guidance Regarding the Interpretation of CCPA Definitions” was removed. The section, included for the first time in the modified regulations released on February 10, 2020, was the subject of numerous comments received by the attorney general’s office, particularly from consumer advocacy groups opposed to it. The now-removed guidance appeared to narrow the definition of “personal information” by confirming that the manner in which the information is maintained by a business could result in the information being outside the scope of the definition of personal information.