Businesses will need to take additional steps to ensure compliance as exemptions under the California Consumer Privacy Act expire at the end of 2022.

By Robert Blamires, Michael H. Rubin, Robert W. Brown, and Jennifer Howes

The California legislature adjourned its 2022 session without extending the exemptions under the California Consumer Privacy Act (CCPA) for personal information collected about California residents in a personnel/HR or business-to-business (B2B) context. Therefore, starting next year all obligations (and rights) in the CCPA, including those introduced under the California Privacy Rights Act (CPRA), will extend to such information.

Aggressive enforcement may be on the horizon now that businesses have had more than two years to comply with California’s landmark privacy law.

By Michael Rubin, Joseph Hansen, Robert Brown, Max Mazzelli, and Wesley Tiu

On August 25, 2022, the California Office of the Attorney General (OAG) announced that it had settled a complaint against Sephora alleging violations of the California Consumer Privacy Act (CCPA). The public settlement was the first since the CCPA became enforceable more than two years ago.