With the clock now running on the comment period for the California Privacy Protection Agency’s (CPPA) Draft Regulations to implement the CPRA – comments are due on August 23 – one of the items on many businesses’ CPRA preparation to-do lists is to address new (and the expansion of existing) consumer rights. The Draft Regulations published by the CPPA lay out how the CPPA is likely to define these obligations. This post takes a deeper look at what’s in the CPPA’s proposal – as well as what’s missing.
A couple of overarching points are worth keeping in mind. First, implementing the CPRA’s consumer rights provides an occasion to review and update data maps so that they accurately capture how personal information flows both through their organizations and to service providers, contractors, and/or third parties. Second, preparing for CPRA consumer requests should go hand-in-hand with reviewing the systems and procedures that are in place to honor consumers’ requests.
Continue Reading Preparing for Expanded Consumer Rights Requests Under the CPRA