Last week, the period for comments closed on the California Privacy Protection Agency’s (CPPA) latest version of the draft implementing regulations for the California Privacy Rights Act (CPRA) amendments to the California Consumer Privacy Act (CCPA) (Revised Regs). The Revised Regs were first released with modifications and an Explanation of Modified Text of Proposed Regulations at the end of October. Shortly thereafter, the CPPA released the current version of the Revised Regs, which, compared to the initial draft regulations (Initial Draft Regs), include many substantive modifications to key compliance areas.

The Agency’s release followed the Colorado attorney general’s publication of the proposed Colorado Privacy Act (CPA) draft rules (Draft Rules), which we analyzed in a prior communication. The Revised Regs differ from the initial draft regulations and the Colorado draft rules in several key respects. Below we outline and analyze some of the key provisions of the Revised Regs.

Read the full blog post here on Perkins on Privacy.