In the first week of December, AFSA’s State Government Affairs team attended the three hearings held by the California Attorney General’s Office on the California Consumer Privacy Act (CCPA) in Los Angeles, Fresno and San Francisco. The AG’s office released proposed regulations implementing the CCPA in October and was accepting written feedback until December 6. These hearings, which each drew over a hundred attendees, provided an opportunity to convey verbal comments on the AG’s proposed regulations.

Speakers at the hearings raised a variety of compliance, operational, and legal concerns and represented a diverse set of interests, including financial institutions, security and compliance companies, law firms, trade associations, and consumer groups. One major issue the speakers raised is the CCPA’s effective date of January 1, 2020. The AG’s office will release its final rules by July 1, 2020, which would require companies to immediately start complying with the rules, but many speakers requested the AG delay compliance for the rules until 2021 or 2022.

The AG’s office will release its final rules by July 1, 2020, which would require companies to immediately start complying with the rules, but many speakers requested the AG delay compliance for the rules until 2021 or 2022. Another issue several speakers raised is that the draft regulations fail to further clarify definitions, including “sale of data,” “household,” “customer,” “service provider,” and “understandable notice.” Speakers also identified several provisions in the draft regulations that lack statutory basis in the CCPA, such as a new requirement for companies to honor a blanket opt-out request through a browser setting or add-on and the requirement that businesses treat unverifiable requests as a sale opt-out.

Although AFSA did not provide comments during the hearings, it submitted written comments before the deadline. As a reminder, AFSA previously commented during the preliminary rulemaking process and attended several of the AG’s earlier public CCPA forums.