On March 10, 2022, California Attorney General Rob Bonta (Attorney General) published the first official opinion interpreting the California Consumer Privacy Act (CCPA) and concluded that the CCPA’s right to know includes a business’ internally generated inferences about a consumer from either internal or external information sources.
Importantly, the opinion clarifies that inferences made from
As we covered at the end of last month, the California Attorney General is targeting loyalty programs in a recent enforcement sweep alleging noncompliance with the California Consumer Privacy Act (CCPA). CPW’s Kyle Dull, a Senior Associate in Squire Patton Boggs Data Privacy, Cybersecurity & Digital Assets Practice, was recently interviewed by Law360 concerning businesses’ data practices in the operation of their loyalty programs. You can check out the Law360 article and his comments here. From the article:
Continue Reading Loyalty Program CCPA Compliance: Kyle Dull Talks to Law360
On July 19, the Office of the Attorney General of California (OAG) issued a press release summarizing its first year of CCPA enforcement. Seventy-five percent of companies receiving a notice to cure are said to have come into compliance within the 30-day cure period, with 25% reportedly still within that period or under ongoing investigation. The OAG also published summaries of 27 resolved exemplary cases. The OAG was careful to note that the summaries do not constitute advice and do not include all of the facts, however they do offer some insights. Disappointingly, however, the summaries often lack enough detail to allow readers to surmise the enforcement posture that was taken by the OAG, the exact nature of the alleged violations, or the specific actions taken by the company that satisfied the OAG’s inquiry.Continue Reading California AG Offers Cryptic CCPA Enforcement Summaries, and Launches Complaint Tool