While still in draft form, the modifications both clarify certain obligations and introduce new uncertainty for businesses covered by the CCPA.

By Jennifer C. Archie, Michael H. Rubin, Robert Blamires, Marissa R. Boynton, and Scott C. Jones

Earlier this month, the California Attorney General released modified draft regulations further clarifying, and in some cases complicating, compliance with the California Consumer Privacy Act. Key developments include narrowing the definition of “personal information,” changing the use limitations on “service providers,” and other amendments affecting how businesses must respond to data rights requests. The regulations must be final by July 1, which means the California AG may still publish another round of modifications after the public comment period closes on February 25. For more information on all key modifications, see our recent Client Alert.