Hundreds of lawyers and several privacy regulators from California, Washington State, Oregon, Colorado, Connecticut, and the Federal Trade Commission gathered in Los Angeles last week for the second annual California Lawyers Association Privacy Summit (“Summit”). Among many engaging sessions on pressing topics, the panels with privacy regulators stood out discussions on enforcement priorities and administrative fines and injunctions, along with punchy and newsworthy statements – including that they are “plotting” and that considering the typical investigation presents “hundreds or thousands of violations,” potential fines are “significant.”
Perhaps even more newsworthy is that due to a California Court of Appeal order laid down as the Summit wound down on Friday, the stay in enforcement of the CCPA regulations was lifted. This happened as many companies were treating March 29, 2024, the end of the stay period, as the effective and enforcement date of regulations promulgated under the CPRA’s amendments by the California Privacy Protection Agency. The appeals order also nullifies the year delay in effectiveness of issued CCPA regulations that the trial court had required, making almost certain that CCPA regulations on risk assessments, cybersecurity assessments, and automated decision-making and profiling will be promulgated and in effect sometime this year, perhaps as early as Q2 or Q3.
Will 2024 be the year of privacy enforcement? In view of signaling from California regulators and those in other jurisdictions, and in view of several upcoming effective dates and regulatory deadlines, ongoing enforcement by regulators in California and beyond, and an impending uptick in privacy enforcement, it just might be. Stay tuned for future posts on these issues. Keep reading for more detailed takeaways regarding the Summit.Continue Reading Potential CCPA Fines “Significant”, California AG’s Office “Plotting” and Other Takeaways From Privacy Regulators during Privacy Summit in Los Angeles