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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 8 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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As we have previously reported, compliance with the now-effective <a href="http://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=CIV&amp;division=3.&amp;title=1.81.5.&amp;part=4.&amp;chapter=&amp;article=">California Consumer Privacy Act (CCPA)</a> continues to be a process of shooting at a moving target. Even though the CCPA became effective on January 1, 2020, the California Attorney General has yet to finalize the implementing regulations he was charged with issuing by the state legislature. California Attorney General Xavier Becerra published the initial draft of CCPA regulations in October of 2019. On February 7, 2020 (and then again on February 10, 2020), his office published modifications to the draft regulations. On March 11, the Attorney General published additional modifications to the draft regulations to clarify and conform the proposed regulations to existing law.

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Here’s a summary of the critical changes made in this second round of modifications:

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All written comments regarding this second set of proposed changes must be submitted to the Attorney General’s office by March 27, 2020. Importantly, the Attorney General has not indicated any intention to postpone the July 1, 2020 enforcement deadline, when the regulations will be completed, or whether they will even be completed prior to the deadline. Accordingly, covered businesses should continue to monitor the regulatory drafting process and update or adjust their compliance programs as needed. We continue to follow developments of the CCPA and will be sure to keep you updated.

Craig A. Foster 614.469.3280 <a href="mailto:Craig.Foster@ThompsonHine.com">Craig.Foster@ThompsonHine.com</a>

Steven G. Stransky 216.566.5646 202.263.4126 <a href="mailto:Steve.Stransky@ThompsonHine.com">Steve.Stransky@ThompsonHine.com</a>

Thomas F. Zych 216.566.5605 <a href="mailto:Tom.Zych@ThompsonHine.com">Tom.Zych@ThompsonHine.com</a>

This advisory bulletin may be reproduced, in whole or in part, with the prior permission of Thompson Hine LLP and acknowledgment of its source and copyright. This publication is intended to inform clients about legal matters of current interest. It is not intended as legal advice. Readers should not act upon the information contained in it without professional counsel.

This document may be considered attorney advertising in some jurisdictions.

https://admin.thompsonhine.com/wp-content/uploads/2022/05/Privacy__Cybersecurity_Update_-_California_Attorney_General_Publishes_Modifications_to_CCPA_Regulations.pdf

California Attorney General Publishes Modifications to CCPA Regulations

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