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The CCPA’s core requirements can be grouped broadly into three categories: (1) rights owed by businesses to Californians concerning their personal data, (2) data security breach risks and obligations, and (3) vendor management.

The CPRA expanded the scope of the first category – i.e., the rights conferred upon Californians concerning their personal data. Under the CPRA, Californians will have the right to fix errors concerning their personal information, to opt out of behavioral advertising, to object to the use of sensitive information, and to object to automated decision making and profiling.   In addition, the CPRA created two additional categories of core requirements: (1) the ability to process and retain data, which requires a company to have a record retention policy and minimize data collected, and (2) business accountability and governance, in which companies will be required to conduct security risk assessments and privacy risk assessments and appoint an employee responsible for privacy compliance.

The following chart compares the main obligations imposed by the CPRA to those that had been imposed by the CCPA:

This chart compares the main obligations imposed by the CPRA to those that had been imposed by the CCPA.

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Photo of Jena M. Valdetero Jena M. Valdetero

Jena M. Valdetero serves as Co-Chair of the firm’s U.S. Data Privacy and Cybersecurity Practice, and is a trusted advisor to clients facing complex and high-stakes data privacy and security challenges. With a track record of leading thousands of data breach investigations for…

Jena M. Valdetero serves as Co-Chair of the firm’s U.S. Data Privacy and Cybersecurity Practice, and is a trusted advisor to clients facing complex and high-stakes data privacy and security challenges. With a track record of leading thousands of data breach investigations for more than 20 years, Jena combines her broad litigation experience with a deep understanding of the evolving privacy landscape to protect her clients’ interests. She is highly skilled in defending companies in privacy and data breach litigation, particularly class actions, and is proactive in helping clients prepare for incidents by designing and facilitating customized tabletop exercises.

Jena offers practical, results-driven counsel on data privacy and security compliance programs and guides clients through privacy and cyber risk considerations in mergers, acquisitions, venture capital, and securities transactions. Her experience spans a wide range of privacy laws, including the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), the Gramm Leach Bliley Act (GLBA), and the Health Insurance Portability and Accountability Act (HIPAA). Certified as a privacy professional through the International Association of Privacy Professionals (CIPP/US),  Jena provides clients with actionable insights on both current and emerging privacy regulations. She previously served as KnowledgeNet Co-Chair for the International Association of Privacy Professionals, further reflecting her leadership in the field. Jena is a founding board member of the Chicago Compassion Project, a nonprofit supporting low-income families in Chicago.

Jena has been recognized by Chambers USA as a leading privacy and data security lawyer, with clients praising her “very deep knowledge of subject matter” and calling her “extremely responsive and business-minded.” She is trusted for her “great strategic advice” and practical approach to complex data privacy issues, with one client saying, “I’d unequivocally recommend her to anybody with any kind of privacy or data breach concerns.”

Photo of David A. Zetoony David A. Zetoony

David Zetoony, Co-Chair of the firm’s U.S. Data, Privacy and Cybersecurity Practice, focuses on helping businesses navigate data privacy and cyber security laws from a practical standpoint. David has helped hundreds of companies establish and maintain ongoing privacy and security programs, and he

David Zetoony, Co-Chair of the firm’s U.S. Data, Privacy and Cybersecurity Practice, focuses on helping businesses navigate data privacy and cyber security laws from a practical standpoint. David has helped hundreds of companies establish and maintain ongoing privacy and security programs, and he has defended corporate privacy and security practices in investigations initiated by the Federal Trade Commission, and other data privacy and security regulatory agencies around the world, as well as in class action litigation.

About Greenberg Traurig

Greenberg Traurig, LLP has more than 3,100 lawyers across 51 locations in the United States, Europe, the Middle East, Latin America, and Asia. The firm’s broad geographic and practice range enables the delivery of innovative and strategic legal services across borders and industries. Recognized as a 2025 BTI “Best of the Best Recommended Law Firm” by general counsel for trust and relationship management, Greenberg Traurig is consistently ranked among the top firms on the Am Law Global 100, NLJ 500, and Law360 400. Greenberg Traurig is also known for its philanthropic giving, culture, innovation, and pro bono work. Web: www.gtlaw.com.

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