The Department of Justice of California published yet another round of draft CCPA (California Consumer Privacy Act) regulations on March 7, 2020 with comments due March 27, 2020.
As stated in the notice, there were “around 100 comments received in response” to the previous draft regulations.
In the most recent version, the “redlined” version is color-coded to easily identify the original draft regulations, the first set of modifications, and this second set of modification. The redlined and clean versions are published online.
According to the rule-making process, if changes are made to the proposed regulations, the changes will be published for the public to submit comments. These comments would be reviewed and based on the comments, either revise or accept the published draft. Comments will also be responded to at the publication of the final regulations. The Office of the Attorney General previously provided guidance that if changes are “substantial and sufficiently related,” the changes will be published with an abbreviated comments period of 15 days (this modification and the last one met these requirements). If changes are not made or are “nonsubstantial and sufficiently related,” no publication for comments will occur. Only “major changes” would require a full 45-day comment period.
Some of the key changes include:
Removal of § 999.302 which was added in the last version addressing that an IP address that ..
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