Welcome to 2020. The California Consumer Privacy Act (“CCPA”) is now in effect, and your business has probably spent significant time and expense preparing for the law. With so much focus on CCPA preparations, it’s important to recall that the CCPA isn’t the only California privacy law to become effective this year. California will now also require any business that meets the definition of a data broker during a given year to register as a data broker with the California Attorney General’s Office on or before January 31st of the following year. Although the law is not clear whether it retroactively applies to business practices in 2019, the California Office of the Attorney General has issued a press statement on data broker registration and posted a registration page, which strongly indicates that the AG expects qualifying businesses to register by January 31, 2020.

Continue Reading

Vermont’s new Data Broker Regulation (“Regulation”) takes effect on January 1, 2019. The Regulation requires, among other things, that data brokers register with the Vermont Secretary State and protect personally identifiable information of Vermont residents. This week, the Vermont Attorney General issued guidance on the Regulation, which helps address questions on process and scope. Below are some of the key takeaways from the Regulation and guidance.

Continue Reading