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Charlotte Kress

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Charlotte Kress counsels clients on a wide range of privacy, security, advertising, and e-commerce matters, including compliance obligations, responding to Federal Trade Commission (FTC) investigations, and internal policy analysis.

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The exemption for employment-related and business-to-business (B2B) data under California’s privacy law expired on January 1, 2023. Without this exemption, information previously allowed to be excluded now falls within the scope of California’s extensive privacy requirements, including notice and transparency, data minimization, and data subject rights requests.

In this blog post, we provide an overview of the now-expired exemptions and offer next steps on the requirements that now pertain to employment and B2B data.Continue Reading With the CPRA Enforcement Deadline On the Horizon, Employment and B2B Data Could Mean Cloudy Skies For Those Unprepared

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.Continue Reading One Step Closer: California Privacy Protection Agency Reviews Comments for CCPA Regulations

Companies doing business in the United States should start preparing for the Utah Consumer Privacy Act, which was signed into law on March 24, 2022, and will go into effect on December 31, 2023. The law is more business-friendly than existing omnibus state privacy laws, in that it generally provides fewer consumer rights and company…