When the California Consumer Privacy Act (CCPA) enters into force on January 1, 2020, it will grant consumers extensive new data rights and place new obligations on companies. This means that just about every company doing business in California or with Californians and meeting certain thresholds (by revenue or data collection) should know about the CCPA, risks for class action litigation and incentives to plaintiff’s attorneys to bring suit in California. While the California Senate Appropriations Committee blocked a bill on May 17 that would expand a private right of action under the CCPA beyond data breaches, business should still anticipate litigation once the CCPA takes effect and build litigation defense considerations into their compliance plans.
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