The California Attorney General’s investigative sweep is a potential harbinger of increased focus on employers’ data privacy compliance with respect to employee data.

By Robert Blamires, Michael H. Rubin, Joseph C. Hansen, and Kathryn Parsons-Reponte

On July 14, 2023, the California Attorney General announced an investigative sweep targeting large California employers, focusing on employers’ compliance with the California Consumer Privacy Act’s (CCPA’s) recently expanded coverage of employees and job candidates. The announcement follows the expiration of a prior exemption for personnel and business to business (B2B) data under the CCPA (for more information, see this Latham blog post).

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

Businesses active in California should promptly assess whether the law applies to their practices and start planning towards compliance with the new law.

By Jennifer Archie, Michael Rubin, and Scott Jones

Key Points:

  • A sweeping new privacy law — the California Consumer Privacy Act of 2018 — was signed into law on June 28, 2018.
  • The Act imposes substantial new obligations on businesses that collect, process, and disclose the data of California residents.
  • The Act was drafted, voted on, and enacted in a matter of days, but it will not go into effect for another 18 months: on January 1, 2020. Given this rushed process, changes to the law before its effective data can be expected.

Facing pressure from a significantly stronger ballot measure in the state, on Thursday, June 28, 2018, the Governor for the State of California signed into law the California Consumer PrivacyAct of 2018 (the CCPA). Effective January 2020, this law ushers in widespread changes to California’s law on the information practices for covered businesses collecting, processing, and disclosing information gathered from or about California consumers or their devices.