Today, the California Office of the Attorney General (OAG) released a second set of modifications to its proposed California Consumer Privacy Act (CCPA) Regulations.
The proposed regulations were first published and noticed for public comment on October 11, 2019. On February 10, 2020, the OAG released modifications to the proposed regulations based on the earlier comments it received. The current, second set of modifications to the proposed regulations are in response to the comments the OAG received in February.
Notably, the current draft of the proposed regulations strikes section 999.302, which purported to provide “guidance regarding the interpretation of CCPA definitions” through an example of when IP addresses may not qualify as “personal information,” as discussed in GT’s February 11 summary, OAG Proposes Significant Changes to CCPA Regulations.
The current draft likewise removes the previous version’s suggested images for an “opt-out button or logo” found in section 999.306(f).
The OAG will accept written comments until Friday, March 27, 2020, at 5:00 p.m. PST.
The Greenberg Traurig Data, Privacy & Cybersecurity team is in the process of reviewing the revised, second set of proposed regulations. Please check back on the Data Privacy Dish blog for further analysis, or contact us to discuss further.