Norton Rose Fulbright - Data Protection Report blog

This is the Data Protection Report’s seventh blog post in series of CCPA blog posts that will break down the major elements of the CCPA. Stay tuned for additional posts on the CCPA.

On January 25, 2019, the California Attorney General’s Office held a public forum in Los Angeles to solicit feedback on the California Consumer Privacy Act of 2018 (“CCPA”) as it prepares to draft regulations which must be adopted on or before July 1, 2020. CCPA provides new rights to California consumers with respect to the collection and use of their personal information. The CCPA authorizes the Attorney General to promulgate regulations that will establish procedures to facilitate consumers’ rights. The Attorney General’s Office does not answer questions at these forums; rather, the forums are designed to solicit feedback on the rulemaking categories enumerated in the text of the law, including, but not limited to, the definition of personal information and rules and procedures for how businesses must comply with a consumer’s request to opt out of the sale of personal information.

The Los Angeles forum was well-attended by a cross section of speakers representing businesses, consumers rights groups, application developers, and universities, among others. Many of the comments echoed the concerns voiced at the San Francisco forum. For instance, privacy attorneys and compliance offices alike requested that the regulations address perceived ambiguities in the law, such as clarifying the definition of “sale” and the scope of GLBA and HIPPA exemptions. Others stressed the need for safe harbor provisions, particularly for companies that that are in compliance with GDPR. On the other hand, consumer rights groups urged the Attorney General to maintain the current expansive definition of personal information and to draft implementing regulations that further enhance the protections already contained in the CCPA. Overall, the comments highlighted the tensions between businesses that are facing the challenge of complying with the new privacy law and consumer rights groups who are pushing to strengthen the law’s provisions.

In addition to the previously-announced five public forums, California Department of Justice has announced a new public forum: March 5 at 12:45pm, Stanford Law School, 559 Nathan Abbott Way, Room 290, Stanford, CA 94305.

Public comments are also accepted by email at or by mail to the California Department of Justice, ATTN: Privacy Regulations Coordinator, 300 S. Spring St., Los Angeles, CA 90013.

The Attorney General’s Office expects to circulate draft regulations by the fall of this year. There will be an opportunity to comment on the draft regulations after they are published.

Our other CCPA articles

Article 1: Summary of CCPA’s major provisions

Article 2: CCPA covered entities

Article 3: CCPA definition of personal information

Article 4: CCPA disclosure requirements

Article 5: CCPA “Right to Deletion”

Article 6: California Attorney General’s Office begins CCPA rulemaking process with first public hearing while Congress debates new federal privacy law

Article 7: Comments at CCPA public forum in Los Angeles highlight tensions between businesses and consumer rights groups

Article 8: GDPR, CCPA and beyond: Changes in data privacy laws and enforcement risks to monitor in 2019

Article 9: CCPA: “Attorney General Amendment” Likely Dead

Article 10: Nevada, New York and other states follow California’s CCPA

Article 11: “What’s cooking” in Sacramento: CCPA’s “employee exception” bill is amended; “publicly available information” exception is broadened, and consumer access rights are clarified

Article 12: Back At The Negotiating Table: CCPA Amendments Debate Continues

Article 13: One-Month Countdown to Pass CCPA Amendments Begins

Article 14: CCPA: “Wait and see” is not the right approach

Article 15: And then there were five: CCPA amendments pass legislature

Article 16: Mic Drop: California AG releases long-awaited CCPA Rulemaking

Article 17: California Governor Signs All 5 CCPA Amendments

Article 18: Here We Go Again: Another Ballot Initiative for CCPA in 2020

Article 19: Privacy Officers’ New Year’s Resolutions

Article 20: State of the Untion: CCPA and beyond in 2020