Despite the Passage of CCPA Employee Amendment, Employers Still Face Significant Compliance Burdens Under California’s New Privacy Law
The California legislature closed its 2019 legislative session in grand fashion, passing a total of five amendments to the California Consumer Privacy Act of 2018, all of which are expected to be signed into law by the California governor. Included in these amendments is Assembly Bill 25, commonly known as the CCPA’s ‘‘employee exclusion’’ amendment.
To the dismay of many employers, however, while an earlier version of AB 25 would have excluded employees altogether from the scope of the CCPA, the version of AB 25 that was ultimately passed by the California legislature stops well short of providing comprehensive ‘‘get out of jail free’’ card for employers that are covered by California’ new sweeping privacy law.
Rather, while offering some benefit to employers by excluding employees from the CCPA’s definition of ‘‘personal information’’ at least until 2021, AB 25 contains two critical carve-outs which—taken together—place substantial compliance obligations on employers that had to be satisfied by the law’s effect date January 1, 2020.
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“Despite the Passage of CCPA Employee Amendment, Employers Still Face Significant Compliance Burdens Under California’s New Privacy Law,” by Jennifer J. Daniels, Ana Tagvoryan, David J. Oberly, Ana Amodaj, and Kathy E. Herman was published in the January 2020 edition of Pratt’s Privacy & Cybersecurity Law Report (Vol. 6, No. 1), an A.S. Pratt Publication, LexisNexis. Reprinted with permission.
This article was first published as a Blank Rome Cybersecurity & Data Privacy client advisory in September 2019.