The California Privacy Protection Agency (the “Agency” or CPPA), the new California state agency created under the California Privacy Rights Act of 2020 (CPRA) to oversee and enforce the California Consumer Privacy Act (CCPA) and the CPRA, has recently called for preliminary public comments on a proposed rulemaking under the CPRA. See the invitation from

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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