Final Amendments To The California Consumer Privacy Act Before It Becomes Effective


The California legislative Assembly and Senate both approved several amendments to the California Consumer Privacy Act (CCPA) set to take effect on January 1, 2020, and become enforceable on July 1, 2020.

First, the CCPA was amended to exclude from its application a business's handling of information about its employees, managers, directors, job applicants and freelancers. It also exempts information about these categories of individuals in a business-to-business relationship. These individuals will not be entitled to most of the rights otherwise afforded by the CCPA to data subjects. However, they are entitled to receive notice from the business describing the types of information collected about them and the purpose of collection. These individuals will still be entitled to the CCPA's private right of action in case of a data breach resulting from the business's failure to maintain reasonable security measures. The CCPA's carve-out for these workforce individuals will expire on January 1, 2021, when the CCPA becomes fully applicable to them.

Another amendment exempts businesses who operate exclusively online and have direct relationship with the data subjects, from the CCPA's requirement to offer a toll-free number for individuals to contact the business and request to exercise the data right. These businesses can make do with an email...

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