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
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
On February 7, 2020, the California Attorney General’s Office (OAG) issued proposed changes to the California Consumer Privacy Act Regulations (Modified Regulations), which were originally issued on October 11, 2019. Organizations have until February 24 to submit written comments on the proposed changes to the regulations implementing the CCPA.
Some of the major