Material privacy and data security risks are set to rise again with the coming implementation of the California Consumer Privacy Act (CCPA). In the midst of uncertainty about final compliance requirements of the CCPA, affected entities’ participation in an upcoming California Attorney General rulemaking proceeding remains vital.
Virtually any business that collects personal information related to California residents and their households may be affected by the CCPA. Administrative penalties and strike suits filed as consumer class actions seem inevitable under the CCPA given experience with similar California consumer legislation in the past decade. The California Attorney General can levy stiff per-violation civil penalties of up to $7,500.
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