Search results for: california consumer privacy act

The California Consumer Privacy Act (CCPA) requires that privacy notices be updated annually, and that the detailed disclosures it proscribes be in those notices reflect the 12-month period prior to the effective (posting) date. Interestingly, failure to make annual updates was one of several alleged CCPA violations that resulted in a recent $1.35 Million administrative civil penalty by the California Privacy Protection Agency (CPPA) against retailer Tractor Supply Company. Also, three more state consumer protection laws go into effect on January 1, 2026, which will require notice and consumer rights intake changes, if applicable. Additionally, new and amended CCPA regulations will bring new obligations for businesses starting the first of the year that need to be addressed between now and then. Also recommended is a general checkup with particular attention to enforcement priorities.

Continue Reading Your Year-end U.S. Privacy “To Do” List – don’t wait until the holiday crush to become 2026-ready

On September 25, the California Privacy Protection Agency (CPPA) Board advanced OAL-approved updates to the California Consumer Privacy Act (CCPA), the process of which we covered in detail here and here, that include long-awaited regulations on cybersecurity audits, risk assessments, and automated decision-making technology (ADMT). The CPPA Board also approved a $1.35 Million settlement with Tractor Supply Company, officially announced this week. At last week’s meeting, staff reported that there were hundreds of investigations and enforcement actions in progress, many of which were at a stage that the applicable businesses were not yet aware that they are a target. 2026 will bring new privacy obligations for businesses and greater repercussions for half-baked compliance efforts.

Continue Reading California Privacy Agency Rolls Out New Regulations and Approves $1.35 Million Penalty in Latest CCPA Enforcement Action

Date: September 10, 2025 at 12:00 PM EDT

Format: Live Video

Duration: 1 Hour

Description: With limited federal regulation on consumer protection, data privacy, and AI, states are stepping in, creating a patchwork of laws that vary widely in scope and enforcement. While California and Colorado set high standards, other states like Maryland, Minnesota, and Oregon are introducing even stricter measures. Additional laws around consumer health data, data brokers, and child/teen online safety further complicate the landscape.

This panel will explore key differences and overlaps in state laws, highlight enforcement trends, and offer practical strategies for enterprises to implement privacy programs across states and globally. Attendees will receive comparison charts to support compliance efforts.

Continue Reading State Privacy and AI Law Updates – A Live Legal Briefing You Won’t Want to Miss

On June 30, 2025, the California Civil Rights Council (CRC) secured final approval for regulations addressing employment discrimination resulting from the use of artificial intelligence and other algorithms it collectively refers to as Automated-Decision Systems. Shortly after that, on July 24, 2025, the California Privacy Protection Agency Board approved its own long-anticipated regulations on cybersecurity audits, privacy risk assessments and automated decision-making technology, also covering human resources applications, under the California Consumer Privacy Act (CCPA). The CRC regulations are effective October 1, 2025. The CCPA regulations are likely to also become effective on that date, but obligations will phase in over time. Read our latest insight on our website to learn how to prepare.

Disclaimer: While every effort has been made to ensure that the information contained in this article is accurate, neither its authors nor Squire Patton Boggs accepts responsibility for any errors or omissions. The content of this article is for general information only and is not intended to constitute or be relied upon as legal advice.

Announcing the July 31, 2025, effectiveness of Minnesota’s strict consumer privacy law (CPL), the Act’s author said in a press release that he will be personally making requests to a “long list of ‘data brokers’ … [to] provide a timely ‘test case’ that we can use to measure compliance….”  Until January 31, 2026, businesses will have 30 days to cure violations.

Continue Reading Minnesota’s Comprehensive Privacy Law Takes Effect – and Enforcement Efforts Begin Immediately

On July 24, the California Privacy Protection Agency Board unanimously voted to approve the May 9 draft of its proposed edits and additions to regulations under the California Consumer Privacy Act (CCPA), which we broke down in detail here.  There were 575 pages of comments from 70 commentators regarding that last set of changes, but staff concluded that no further changes were appropriate in response to these comments and the Board agreed.  So now, a final package will be prepared and presented to the Office of Administrative Law (OAL) to confirm the regulations are consistent with the CCPA and administrative procedures.  That package will include more detailed explanation of why rejected comments were rejected, with the goal of providing guidance especially regarding interpretation issues.  Assuming OAL approval, key implementation dates will be:

Continue Reading New California Privacy Regulations Passed by Board

In another settlement of a cookie-related state consumer privacy law enforcement action, California reinforces contract requirements for making personal information available and raises questions about the scope of purpose limitation requirements, especially where the nature of the data and/or its use could run counter to consumer expectations. 

On July 1, 2025, the California Office of the Attorney General (OAG) announced a settlement against Healthline, which included the largest CCPA settlement to date – $1.55 million – and many “firsts” for public CCPA enforcement: the first involving a publisher, the first health information-related enforcement action, and the first time the purpose limitation principle has been invoked by California’s (or any other state’s) regulators in a public regulatory enforcement context. This enforcement action came just a week before Connecticut’s attorney general announced an $85,000 settlement under the Connecticut state privacy law explored in more detail here.

Continue Reading California AG Issues Highest Fine to Date for CCPA Violations

Many organizations have been working diligently to comply with the 13 state consumer privacy laws (CPLs) in effect in the first half of 2025 (14 if you count Florida). Some have chosen to comply on a state-by-state basis and others have followed the high-watermark approach of applying the strictest standard from among the CPLs to all states with CPLs or on a nationwide basis. Regardless of the chosen approach, the next six months brings a new batch of CPLs, some with material differences from the earlier generations, starting as early as July 1, 2025. In addition, amendments to CPLs already in effect will bring new obligations and requirements for many businesses during the second half of 2025. Accordingly, if these changes were not prospectively addressed, now is the time to confirm which of new CPLs are applicable, and timely revise privacy notices and compliance program procedures. Also, with the increase in CPL enforcement, and the growing size and frequency of civil penalties, now is also a good time for an overall privacy compliance checkup. 

(A list of the 20 CPLs and their effective dates and applicability thresholds is included in an appendix at the end.)

Continue Reading The Second Half of the Year Brings New State Privacy Obligations – Are You Ready?

State consumer privacy enforcers have been turning up the heat on recalcitrant data controllers that have incomplete, inadequate or broken consumer privacy law (CPL) protection programs.  On July 8, the Office of the Attorney General of Connecticut (CT OAG) announced a settlement with TicketNetwork, Inc related to deficiencies in the company’s privacy notice and non-compliance with consumer rights requirements. This came just a week following California’s announcement of its largest consumer privacy law settlement to date — US $1.55 million, involving an online publisher known as Healthline. A post breaking that case down will follow shortly.  Today we look at the Connecticut case.

Continue Reading Connecticut’s Recent Privacy Settlement Shows that Organizations Should Remain Cognizant of Privacy Law Obligations Outside of California

The rulemaking process on California’s Proposed “Regulations on CCPA Updates, Cybersecurity Audits, Risk Assessments, Automated Decisionmaking Technology, and Insurance Companies” (2025 CCPA Regulations) has been ongoing since November 2024.  With the one-year statutory period to complete the rulemaking or be forced to start anew on the horizon, the California Privacy Protection Agency (CPPA) voted unanimously to move a revised set of draft regulations forward to public comment on May 1, which began May 9 and closes at 5 pm Pacific June 2, 2025.  The revisions cut back on the regulation of Automated Decision-making Technology (ADMT), eliminate the regulation of AI, address potential Constitutional deficiencies with regard to risk assessment requirements and somewhat ease cybersecurity audit obligations.  This substantially revised draft is projected by the CPPA to save California businesses approximately 2.25 billion dollars in the first year of implementation, a 64% savings from the projected cost of the prior draft.

Continue Reading Revised Draft California Privacy Regulations Lessen Impact on Business