Karen Wentzel

Welcome to our post highlighting key compliance issues under the California Consumer Privacy Act (CCPA). For a broader look at CCPA, please read our prior posts regarding applicability, gap assessments, and the recent amendments, and remember to register for our upcoming webinar covering the final requirements of the law on October 17, 2019. Stay tuned for our next post, “I’m a B2B Company – What Do I Need to Do under CCPA?”


If CCPA applies to your organization and you employ California residents, you may be rejoicing after the recently passed amendments. On September 13, 2019, the California Senate and Assembly passed bills including a limited moratorium for specific types of worker data (as defined below) and the bills are expected to be signed by the Governor soon.

The carve-out is generous, but it is not unlimited. In short, using worker data for any purpose other than employment-related purposes will likely result in the data falling outside of the scope of the exemption, and employers are still required to provide notice.

Unless the moratorium is extended or a permanent carve-out is adopted in the next legislative session, CCPA will apply in full to all worker data effective January 1, 2021.
Continue Reading I’m an Employer – What Do I Need to Do under CCPA?