ANALYSIS: Keeping California Privacy Notices Out of Reach

Undoubtedly, public-facing notices are the low-hanging fruit in the orchard of privacy compliance. A bushel of enforcement letters sent by the California Attorney General’s Office last July reportedly addressed notification-related violations of the California Consumer Privacy Act (CCPA). To ensure that easy enforcement pickings won’t be available when the California Privacy Rights Act (CPRA) becomes operational in 2023, compliance professionals should plan now, before overripe CCPA notices go to seed.

The CPRA, to its credit, does not increase the number of required notices, and it provides a nearly two-year time frame to make each consumer notification peach perfect. Still, the ...