Damon W. SilverBlog Posts

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  • CPPA Starts Rulemaking on Cybersecurity, Risk Assessments, and Automated Decision-making

    While the California Privacy Protection Agency (CPPA) only recently approved revised amended regulations pertaining to the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), it is already on to its next rulemaking. On February 10, 2023, the CPPA issued an invitation for preliminary comments on proposed rulemaking pertaining to cybersecurity audits,...
    February 22, 2023
  • California Privacy Protection Agency Passes Revised Regulations

    After a significant delay, on February 3, 2023, the California Privacy Protection Agency (CPPA) unanimously approved amended regulations. The new regulations have not yet gone into effect as they must first be approved by the Office of Administrative Law (OAL). The CPPA’s General Counsel advised that there is no guarantee that the regulations would be...
    February 8, 2023
  • California Privacy Protection Act Ends 2022 Without CPRA Regulations, But CPPA Targets Risk Assessments and AI for Additional Rulemaking

    On December 16, 2022, the California Privacy Protection Agency (CPPA) had its final meeting before the California Privacy Rights Act (CPRA) which amended the California Consumer Privacy Act takes effect on January 1, 2023. Despite the CPRA taking effect at the start of the year, the CPPA, the agency charged with implementing the law, has...
    December 20, 2022
  • CPPA Board Publishes Second Modification to CPRA Regulations

    In June 2022, the California Privacy Protection Agency (CPPA) Board first started discussions about revising the regulations previously released by the California Attorney General. In October, the Board released proposed modifications to the regulations in advance of a planned Board meeting. Since then, the Board has rescheduled both Board and public meetings. The Board seems...
    November 7, 2022
  • CPPA Board Publishes Proposed Modifications to CPRA Regulations in Advance of October Meeting

    On October 21 and 22, the California Privacy Protection Agency (CPPA) Board will meet to discuss possible action regarding the proposed regulations for the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA). Previously, in June 2022, the Board met to discuss revising the regulations previously released by the California Attorney General.  ...
    October 18, 2022
  • California Consumer Privacy Act FAQs: Employment Information

    1. What’s changing? Under the current version of the California Consumer Privacy Act (“CCPA”), an employer’s obligations related to the personal information it collects from employees, applicants, and contractors residing in California (collectively, “Employment Information”) are relatively limited.  Specifically, it needs to (1) provide those individuals a “notice at collection” that discloses the categories of... Continue Reading
    September 27, 2022
  • California Consumer Privacy Act FAQs: Employment Information

    1. What’s changing? Under the current version of the California Consumer Privacy Act (“CCPA”), an employer’s obligations related to the personal information it collects from employees, applicants, and contractors residing in California (collectively, “Employment Information”) are relatively limited.  Specifically, it needs to (1) provide those individuals a “notice at collection” that discloses the categories of...
    September 27, 2022
  • CPPA Releases Notice of Proposed Rulemaking

    At the start of June, the California Privacy Protection Agency (CPPA), the agency tasked with implementing and enforcing the California Privacy Rights Act (CPRA) which amended the California Consumer Privacy Act (CCPA), voted to begin the rulemaking process. On July 8, 2022, the CPPA officially began the formal rule-making process to adopt proposed regulations implementing...
    July 8, 2022
  • $600,000 Reasons To Review Your SHIELD Act Compliance Program: NY Attorney General Announces Significant Settlement Stemming From Email Data Breach

    On January 24, 2022, New York Attorney General Letitia James announced a $600,000 settlement agreement with EyeMed Vision Care, a vision benefits company, stemming from a 2020 data breach compromising the personal information of approximately 2.1 million individuals across the United States, including nearly 99,000 in New York State (the “Incident”). This settlement was the...
    February 16, 2022
  • California Consumer Privacy Act, California Privacy Rights Act FAQs for Covered Businesses

    The California Consumer Privacy Act (CCPA), considered one of the most expansive U.S. privacy laws to date, went into effect on January 1, 2020. The CCPA placed significant limitations on the collection and sale of a consumer’s personal information and provides consumers new and expansive rights with respect to their personal information. Less than one...
    January 19, 2022

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