Gregory P. Szewczyk

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In a surprising development, the California Privacy Protection Agency (CPPA) published proposed amendments to the CCPA regulations recently.  The proposed amendments were initially made public in a package of materials to be considered by the CPPA at its upcoming June 8 meeting.  The proposed amendments—which in effect are the draft CPRA regulations—were issued without advance notice, ahead of the schedule previously announced by the CPPA. … Continue Reading

The California Privacy Protection Agency (“CPPA”) scheduled a Board Meeting for June 8th, in which it will be discussing and possibly taking action with regard to the much anticipated CPRA enforcing regulations.  To facilitate this discussion, the CPPA included a draft of the proposed regulations as part of the meeting records. … Continue Reading

Businesses with automatic renewal contracts—including subscriptions—should take note of Colorado’s new law that went into effect earlier this year on January 1, 2022.  While companies subject to other state’s auto-renewal laws and the Restore Online Shoppers’ Confidence Act (“ROSCA”) will be familiar with the three-prong approach of upfront clear disclosure, simple cancellation, and ongoing reminders, the Colorado law goes a step further by imposing notice obligations on month-to-month renewals.

… Continue Reading

Following the lead of California, Colorado, and Virginia, Utah is set to become the fourth state to pass a comprehensive privacy law.

As of March 4, the Utah Consumer Privacy Act (SB 227) cleared both houses of the Utah legislature.  The UCPA closely resembles the Virginia Consumer Data Privacy Act, but with some interesting changes. … Continue Reading

On December 18, 2020, the Office of the Comptroller of the Current (OCC), Federal Reserve Board (FRB), and Federal Deposit Insurance Corporation (FDIC) announced an interagency notice of proposed rulemaking that would require supervised banking organizations to provide notification of significant computer security incidents to their primary federal regulator.  Under the proposed rule, for incidents that could result in a banking organization’s inability to deliver services to a material portion of its customer base, jeopardize the viability of key operations of a banking organization, or impact the stability of the financial sector, the banking organization must notify its primary federal regulator no later than 36 hours after determining an incident has occurred. … Continue Reading

The California Attorney General’s Office recently released a fourth set of proposed regulatory modifications to the California Consumer Privacy Act (the “CCPA”).

As background, the Attorney General’s Office had only just recently given notice of a third set of modifications on October 12, 2020.  The third set of modifications revised the regulations relating to the notice of a consumer’s right to opt-out of the sale of their personal information. … Continue Reading

On November 4, 2020, California voters approved of the ballot initiative Proposition 24, more commonly known as the California Privacy Rights Act (the “CPRA”).  The CPRA goes into effect on January 1, 2023, and will expand several of the existing protections in the California Consumer Privacy Act (the “CCPA”).

As background, the original CCPA emerged in 2018 as a compromise between legislators and the advocacy group, Californians for Consumer Privacy, which had secured a ballot measure vote for its proposed privacy law. … Continue Reading

On August 14, 2020, the California Office of Administrative Law (“OAL”) approved in part and withdrew in part the Regulations regarding the California Consumer Privacy Act (“CCPA”).  While most of the changes are non-substantive, the OAL withdrew certain provisions of the Regulations and resubmitted them to the Attorney General’s Office for further review. … Continue Reading