It’s the final (CCPA) countdown: Take a deep dive into the California Attorney General’s Final Statement of Reasons.

  • Direct enforcement against service providers
  • Scope of processing permitted by service providers clarified
  • Requirement to downstream service provider obligations
  • Prohibition against dark patterns
  • How to handle an opt-in after a global privacy choice opt-out

The California AG submitted a package with final regulations. The final version submitted is essentially identical to version three of the regs issued in early March 2020. These and other interesting insights into the reasoning and thinking of the California AG for the revisions made to the regulations can be gleaned from the Final Statement of Reasons submitted to the California Office of Administrative Law, together with the final version of the regs.

Get details in my client alert.