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Major CCPA Impacts Stem From California AG Updates

Monday, July 26, 2021 In an effort to help consumers bring concerns of noncompliance with the California Consumer Privacy Act (CCPA) to covered businesses, the California Attorney General has created a tool to assist consumers with drafting notices of noncompliance that can be sent to businesses that may have violated the CCPA. The California Attorney General has stated that the submission of a notice of noncompliance created through the tool may trigger the 30-day cure period under the CCPA. That means that if a business does not address the alleged noncompliance in 30 days, the California Attorney General may bring suit and seek civil penalties or an injunction.

California Consumer Privacy Act FAQs: Discovery; Tokenization

Friday, January 8, 2021 Circumventing discovery: Can plaintiffs’ attorneys use CCPA access requests to obtain unsupervised discovery? Litigants traditionally look to the rules of civil procedure in order to get discovery in a litigation. Plaintiff’s attorneys have, however, begun to try to circumvent restrictions within the discovery rules that are designed to limit the number, type, and timing of information requests, by sending out “access requests” on behalf of their clients under the California Consumer Privacy Act (CCPA). Nothing within the legislative history of the CCPA suggests that it was intended to replace or supplant the discovery process set forth in the Federal Rules of Civil Procedure and in the California Code of Civil Procedure. Furthermore, one interpretation might be that forcing a civil litigant to disclose personal information outside of judicially proscribed and monitored discovery processes could improperly “restrict a business’ abilit

CCPA Access Request for Litigation and Quasi Discovery

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California Data Privacy & Law Firms: CCPA s CPRA Amendments

Friday, December 18, 2020 Are law firms considered businesses or service providers of the personal information that they receive from clients as part of a representation? It depends. If a written contract between a law firm and its client (e.g., an engagement letter) prohibits the law firm from using, retaining, and disclosing personal information except to the extent permitted by the client, the law firm may be a “service provider” under the CCPA.  The CPRA amended the CCPA’s definition of service provider such that, beginning on January 1, 2023, the contract between a law firm and its client may also need to include provisions prohibiting the sale or sharing of personal information, and the combination of personal information between and among clients of the law firm.

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