Much changed in the privacy law landscape in 2020, including a heightened focus on the use and disclosure of health information. As 2021 gets underway, businesses should be aware of the key legislative and regulatory changes in health data privacy that were teed up at the close of 2020, and which may now or soon
It depends.
If a written contract between a law firm and its client (e.g., an engagement letter) prohibits the law firm from using, retaining, and disclosing personal information except to the extent permitted by the client, the law firm may be a “service provider” under the CCPA. The CPRA amended the CCPA’s definition of service
The regulations implementing the CCPA discuss the education of employees regarding CCPA related responsibilities in two sections:
| Section 999.317(a) | Section 999.317(g)(3) |
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All individuals responsible for handling consumer inquiries about the business’s privacy practices or the business’s compliance with the CCPA shall be informed of all of the requirements in the CCPA and these regulations and |
The CCPA does not explicitly reference the requirement to train employees, but it does require that:
All individuals responsible for handling consumer inquiries about the business’s privacy practices or the business’s compliance with this title are informed [concerning the CCPA’s requirements] . . . and how to direct consumers to exercise their rights under those
No.
The CCPA defines “deidentified” data as information that “cannot reasonable identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to a particular consumer.”1 A number of individuals and entities requested that the Office of the California Attorney General provide guidance as to what steps should be
Marginally.
Section 1798.150 of the CCPA permits consumers to “institute a civil action” if consumer “personal information, as defined in subparagraph (A) of paragraph (1) of subdivision (d) of Section 1798.81.5, is subject to unauthorized access and exfiltration, theft, or disclosure,” and where that unauthorized access was “a result of the business’s violation” of a
On December 10, 2020, the California Attorney General (AG) released the Fourth Set of Proposed Modifications to the California Consumer Protection Act (CCPA) Regulations, styled as “Modifications to Proposed Modifications.” The Fourth Set comes shortly after the comment period for the Third Set of Proposed Modifications closed on Oct. 28. Per the AG’s Notice
One week into the final month of what has been a memorable 2020, maintaining an organization’s privacy hygiene is more pressing than ever – and includes new requirements.
From privacy policy updates mandated by the California Consumer Privacy Act (CCPA), to all businesses needing to stay current and non-deceptive in their public disclosures in relation
Greenberg Traurig Shareholder David A. Zetoony will be delivering the keynote remarks at the 2nd Annual ISACA Forum on CCPA taking place virtually on Thursday, November 19, 9:00 am – 4:00 pm PST. Attendance at this year’s virtual Forum is complimentary. If you are interested in attending, please register online here.
Greenberg Traurig Shareholder David A. Zetoony will be a speaker during American Lawyer Media’s webcast, “How to Adapt Your Incident and Breach Response Strategy to Today’s Regulatory Environment,” on Wednesday, November 18, at 2 PM EST / 11 AM PST.
In today’s ever-changing regulatory landscape, it is vital for legal professionals to build an incident