California Attorney General

2022 saw cases continue to be filed under the California Consumer Privacy Act (“CCPA”), although perhaps reflecting the increasing reliance of the plaintiffs’ bar on negligence and tort-based privacy claims concerning a defendant’s alleged failure to maintain “reasonable security,” the number of cases of CCPA based claims declined. Read on for Privacy World’s highlights of

California Attorney General Rob Bonta announced today an investigative sweep of mobile apps, focused on popular apps in the retail, travel, and food service industries that fail to comply with the California Consumer Privacy Act (CCPA). According to a press release, the sweep is focused on apps that allegedly fail to comply with consumer opt-out requests or do not offer any mechanism for consumers who want to stop the sale of their data. The press release also highlights enforcement in relation to handling of agent requests, namely through an agent service created by Consumer Reports called “Permission Slip.”

Continue Reading California AG Announces CCPA Compliance Sweep of Mobile Apps ahead of Data Privacy Day

In case you missed it, below are recent posts from Privacy World covering the latest developments on data privacy, security and innovation. Please reach out to the authors if you are interested in additional information.

California Federal Court Dismisses GPS Data Tracking Privacy Class Action in Ruling of First Impression For CIPA Claims Involving Devices

2022 was another eventful year in the realm of privacy, security and innovation.  Privacy World was there every step of the way, to keep you informed on key developments.  Starting next week, we will be rolling out our popular Year in Review series.  As a lead up to that, below are our ten most popular

Amendments to the California Consumer Privacy Act (“CCPA”) went into effect on January 1 of this year, as did Virginia’s new privacy law. Virginia’s law is immediately enforceable. While the California amendments are not enforceable until July 1, 2023, on December 31, 2022 the opportunity cure violations before civil penalties could be assessed sunset (at

In case you missed it, below are recent posts from Consumer Privacy World covering the latest developments on data privacy, security and innovation. Please reach out to the authors if you are interested in additional information.

CPW’s Shea Leitch and Kyle Dull to Speak at ACC South Florida’s 12th Annual CLE Conference

CPW’s David Oberly

Shea Leitch (Of Counsel, Washington, DC) and Kyle Dull (Senior Associate, New York/Miami) will speak on Friday, September 16, at the Association of Corporate Counsel (ACC) South Florida Chapter’s 12th Annual CLE Conference, “Casino Royale: Accepting the In-House Mission.” Shea and Kyle’s aptly named panel, “For Your Eyes Only: Dealing with Security Risks, New

The California Consumer Privacy Act (CCPA) currently has limited carve-outs for personal information (PI) collected from a job applicant, employee, owner, director, officer, medical staff member, or independent contractor of a business acting in such capacity (including, without limitation, communications, emergency contact and benefits PI) (HR data). An even broader exception applies to B-to-B communications and related PI (e.g., vendor, supplier and business customer contacts and communications) (B-to-B data). As a result, businesses subject to the CCPA are not currently required to honor CCPA rights requests received from persons concerning HR data and B-to-B data. These carve-outs are set to sunset on January 1, 2023, when the California Privacy Rights Act (CPRA), which substantially amends the CCPA, goes into full effect, at which point HR data and B-to-B data will be fully subject to all of the requirements of the CCPA/CPRA. Many business administrators had hoped that either the California legislature would extend the HR data exceptions (or maybe even make them permanent), or a federal law that limited data subject rights to traditional consumers would pass and preempt CCPA/CPRA. It is now clear that the former is impossible and the latter is highly unlikely. Accordingly, many companies have a lot to do by year-end to prepare to stand up a CCPA/CPRA program for HR data and B-to-B data.

Continue Reading HR and B-to-B Data Compliance Deadline Looming – Legislative Efforts to Extend California Consumer Privacy Act Exemptions Fail

On August 24, 2022, California Attorney General Rob Bonta issued a press release announcing the first public settlement by the Office of the Attorney General (OAG) involving alleged violations of the CCPA. The settlement involves a judicial judgment, civil penalties and ongoing monitoring and reporting. The use of noncompliance letters to cajole companies into compliance over many months now appears to be a closed chapter in the CCPA saga. Season 2 promises more drama, more action and more money. Entertaining unless you are the next target!

Continue Reading The Cookie Crumbles – Lessons from First California Consumer Privacy Act (CCPA) Monetary Settlement

On Tuesday, April 5, CPW’s Alan Friel joined forces with Rebecca Perry, Director of Strategic Partnerships at Exterro, to share their expertise during the “Preparing for 2023 – Tools and Tips to Be Ready for New US Privacy Laws” webinar hosted by Global Data Review.

During this one-hour long virtual session, the duo discussed