Enforcement of the California Consumer Privacy Act (CCPA) began July 1, 2020. Our privacy team at Troutman Pepper includes several attorneys who worked in an attorney general’s office. This privacy regulatory team has identified six areas of enforcement likely to catch the California Office of the Attorney General’s (OAG) attention, which arguably holds sole regulatory enforcement authority under the Act. This six-part series will focus on those areas of the law. Building on the experience of advising clients on the CCPA since its passage, our privacy compliance team will then discuss discrete strategies to minimize enforcement risk and bolster compliance efforts.

Below is the tentative schedule for this six-part series. This week’s alert focuses on failing to provide adequate notice at collection and can be found here.

• Enforcement Area No. 1: The Infamous “Do-Not-Sell” Button
  Available: here

• Enforcement Area No. 2: Treating the CCPA Like a Check-the-Box Exercise
  Available: here

• Enforcement Area No. 3: Service Providers
  Available: here

• Enforcement Area No. 4: Businesses Collecting Children’s Personal Information and Health Related Data
  Available: here

• NEW: Enforcement Area No. 5: Failing to Provide Adequate Notice at Collection
  Available: here

• Enforcement Area No. 6: OAG’s Reaction to CPRA Referendum
  Release Date: August 17, 2020

• Complimentary Webinar: Strategies to Prepare for Six Potential Target Areas of CCPA Enforcement by the CA Attorney General
  August 19, 2020 2 p.m. EST
  Register here