The IAPP Europe Data Protection Congress 2022, Europe’s premier gathering of data protection professionals discussing strategic developments in regional and international data privacy, will be held in Brussels Nov. 16-17. Several members of our Data Privacy & Cybersecurity Group will be in attendance, and we are excited to see everyone there. If you or
Greenberg Traurig
Are law firms considered businesses or service providers of the personal information that they receive from clients as part of a representation?
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…
Are all businesses required to train their employees, or just those that collect large quantities of personal information?
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) |
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 |
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Are businesses required to train their employees about the CCPA?
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…
Does the CCPA adopt a specific standard for deidentifying information?
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…
The CCPA’s “Final Regulations” Are Changing – A Summary of OAL’s Third and Fourth Sets of Proposed Modifications
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…
Privacy Compliance Action Items for Businesses Before EOY 2020
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…
2nd Annual ISACA Forum on CCPA
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.
Webcast: How to Adapt Your Incident and Breach Response Strategy to Today’s Regulatory Environment
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…
EDPB Guidance on Supplementary Transfer Measures and Surveillance Calls Into Question Future Use of SCCs for Data Transfers to US
* Please note, post publication the EDPB extended the deadline for public comments on the Supplementary Transfer Measures Recommendations to Dec 21, 2020.
On Nov. 11, the European Data Protection Board (EDPB) published Supplementary Transfer Measures Recommendations and Surveillance Recommendations.
Click here to read the full GT Alert, “EDPB Guidance on Supplementary Transfer…