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CPPA Sets New Risk Assessment Standard with Release of Draft Rules

The CPPA is continuing to provide operating rule guidance, getting more serious about the need for organizational risk assessment & full understanding of your organization’s data and usage/retention of Personal Information. While these are just draft rules, with the potential for change, we don’t anticipate they will diverge drastically. The Risk Assessment Regulation draft covers…
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AG Bonta Foreshadows Enforcement with Latest Sweep of Connected Car Inquiry Letters

The list of industries being targeted for privacy enforcement is continuing to grow. California Attorney General Rob Bonta has announced that his next wave of privacy reviews is aimed at connected vehicle manufacturers and related technologies. Vehicles are connected to their operators in a way they never have been before, underlining privacy issues with “location…
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Self-Evaluation Is Attorney General Bonta’s Latest Enforcement Strategy

Large California employers are on Attorney General Rob Bonta’s radar and the latest to see a wave of communications from the AG. When CPRA was introduced as an update to the CCPA it was apparent that employment data was going to be an important part of compliance. However, with rulemaking hitting speed bumps and enforcement…
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Is a Federally-Mandated Privacy Law Coming to the Financial Services Market First?

A draft of a bill on financial data privacy from U.S. Rep. Patrick McHenry, Chairman of the Financial Services Committee, was addressed by the House Financial Services Committee Subcommittee on Financial Institutions and Monetary Policy during the “Revamping and Revitalizing Banking in the 21st Century,” on February 8th. The bill “modernizes Gramm-Leach-Bliley Act Using a…
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Why Should I Care About the CPPA Rulemaking in Context of a Video Rental Law from the 1980s?

We’re still potentially 2 months out from getting finalized rulemaking from the CPPA, but there has been some important information trickling out in the meantime. Recently, the CPPA has touched on notices, contracts, and opt-out mechanisms like GPC. As the Video Privacy Protection Act (VPPA) is causing a stir amongst large companies, this will tie…
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From the Desk of Dan Clarke: AG Bonta Discusses Authorized Agents

This year’s Data Privacy Day on January 28th must have inspired Attorney General Rob Bonta as he made an announcement emphasizing his expectation for organizations to step up their privacy compliance. AG Bonta’s statement included notice of a widespread investigation into mobile apps that are not meeting the requirements of the California Consumer Privacy Act.…
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January 2023 Privacy Legislation: The States to Watch

States are ramping up in the new year with more proposed legislation in the absence of movement on federal law. In the coming months, the Colorado Privacy Act and Connecticut Personal Data Privacy and Online Monitoring Act will go into effect on July 1st, the Utah Consumer Privacy Act hits on December 31st, and other…
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CPPA Prioritizing Assessments Beyond Privacy

As the CPPA continues to meet on CPRA regulations and define requirements & enforcement initiatives, there has been a heavy emphasis on assessments. With new laws going into effect that require privacy risk assessments, US companies have to make completion a top priority this year. The value of assessments cannot be overstated, especially as privacy…
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CPPA Timeline Update & Compliance Considerations

On January 1, 2023 CCPA gave way to the amended and expanded CPRA to regulate data privacy for US companies that buy, sell, or share the personal information of 100,000+ California consumers or households or meet other criteria. However, uncertainty remains as rulemaking by the California Privacy Protection Agency is still up in the air,…
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California Privacy Protection Agency Timeline Update

Although there was some doubt that finalization might happen in February, the California Privacy Protection Agency stated that they are expecting to confirm the initial operating rules for the California Privacy Rights Act by the end of January. If rules are released in January, this suggests a start date of late March or, more likely,…
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Newly Proposed Digital Personal Data Protection Bill of India Introduces Upated Privacy Requirements for the Region

After the government dropped its Personal Data Protection Bill earlier this year, India’s parliament published the Digital Personal Data Protection Bill in late November as a second attempt at a comprehensive data privacy law for the region. Despite having many of the same elements as the other bill, the present draft is more succinct, focused…
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Recap of the Upcoming Virginia Consumer Data Privacy Act

There’s been much ado about preparation for privacy in 2023 with a heavy emphasis on CPRA as it transitions from the previously established CCPA, but organizations are up against the effective date for the Virginia Consumer Data Privacy Act, as well. Although both laws provide detailed definitions of “personal information,” grant customers control over their…
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Is Snapchat’s Privacy Toggle the Future for Social Media Companies?

Snapchat is the latest social media platform to adjust privacy settings for users with a recently implemented toggle switch in its privacy controls that allows users to “limit the use of personal information” based on CPRA requirements. So, what’s the big deal? The implementation of this toggle is significant for two reasons: Other social media…
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Truyo’s Takeaways on Latest CPPA Meeting for Pre-Rulemaking

On March 29 & 30, the California Privacy Protection Agency (CPPA) which governs California Privacy under both CCPA and CPRA had what Truyo president Dan Clarke dubs the most meaningful meeting thus far, foreshadowing the agency’s upcoming priorities. Here are his expert thoughts on each of the categories discussed. Pay Particular Attention to Global Opt-out…
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Utah Legislation Update & A Guide to Privacy Impact Assessments for CPRA, CPA, and VCDPA

In the United States, privacy impact assessments are quickly becoming one of the trending requirements of new legislation and proposed bills. CPRA, CPA, and VCDPA all have privacy impact assessment requirements, and as 2023 approaches rapidly organizations should be thinking about how to complete assessments, where to store them, and reporting on assessment outcomes. The…
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The California Privacy Protection Agency Is Not Wasting Time

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California Enforcement Agency (CPPA) to Make Compliance Essential for Businesses

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Prop 24 (CPRA/CCPA 2.0) Has Passed: What This Means For You

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CPRA is on the Horizon – What’s the Ripple Effect?

CPRA would allow consumers the right to correct their data, potential exemptions for unstructured data in right to know requests, the creation of a category for sensitive information, and stricter rules for protecting a minor’s data by tripling the fines associated with violating a minor’s privacy rights.
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California Legislature Further Delays B2B & Employee Privacy Rights
