The California Privacy Protection Agency (CPPA) Board, created by the California Privacy Rights Act (CPRA), has been busy of late. As we recently reported, the CCPA has hired renowned privacy technologist Ashkan Soltani as its new Executive Director to lead the agency. Meanwhile, the agency’s committees have been hard at work. The Regulations Subcommittee has proposed its framework for its rulemaking process. Notably, the subcommittee recommends an immediate start to pre-rulemaking activities such as issuing an invitation for comments, the creation of additional subcommittees, and the identification of informational hearing topics. A pre-rulemaking process gives the agency flexibility to hear from stakeholders outside of the formal and constrained process that will begin once the regulatory process officially commences. The framework also notes that the notice of proposed rulemaking, initial statement of reasons (ISOR), and text of the regulations should be published in winter 2021-2022, with public hearings taking place thereafter. This suggests that stakeholders have a short window of opportunity to take advantage of the pre-regulatory educational period. It will be interesting to see if the agency conducts the kind of “listening tour” the Office of Attorney General (OAG) went on across the Golden State by means of town halls prior to its California Consumer Privacy Act (CCPA) rulemaking process, or elects to spend its time in more intimate and concerted explorations.
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