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The California Attorney General Issues a Modified Draft of the CCPA Regulations

Publications / Feb 27, 2020

Article written by Adi Shoval

The California Attorney General issued a revised draft of regulations under the Consumer Privacy Protection Act (the “CCPA”). In the revised version of the regulations, the Attorney General clarifies certain issues and questions it received from public comments on its first draft.

The modified regulations clarify that information will be considered personal information under the CCPA only where it identifies, relates to, describes, or is reasonably capable of being associated with or linked to a particular consumer or household. The modified regulations illustrate that a business that collects IP addresses of visitors of its website but does not link the IP addresses to any particular consumer or household and could not reasonably do so, will not be considered to be collecting personal information and such collection will not be subject to the CCPA.

The modified regulations further clarify that a business that operates solely online will not be required to provide two methods for consumers to submit requests (including a toll-free number) and that providing an email address for such requests suffices.

The modified regulations include various additional instructions, such as instructions on the verification procedure of a consumer or household request, the notice to be provided to consumers at the time of collection of personal information for different types of businesses, and further instructions on the opt-in process required where a business sells consumers’ information.

CLICK HERE to read the revised CCPA Regulations.