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Perkins on Privacy

Perkins on Privacy keeps you informed about the latest developments in privacy and data security law. Our insights are provided by Perkins Coie's Privacy & Security practice, recognized by Chambers as a leading firm in the field.

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August 6, 2020

The AG Publishes Its FAQs on the CCPA

The attorney general's office has posted a set of FAQs and corresponding responses on its California Consumer Privacy Act (CCPA) site. While aimed at providing guidance to consumers about the CCPA, the FAQs can also serve as a quick reference for businesses regarding their CCPA compliance obligations.

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June 15, 2020

CCPA Compliance: Financial Incentives Requirements

The California Consumer Privacy Act of 2018 (CCPA) regulates a company's offerings of financial incentives and price or service differences related to the collection, retention, or sale of personal information. Cal. Civ. Code Section 1798.125(a)(2); Final Text of CCPA Regulations, 999.301(j), 999.307, 999.336.

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April 2, 2020

CCPA in Litigation: 2018 to Present

The California Consumer Privacy Act (CCPA) went into effect three months ago, on January 1, 2020. Although enforcement by the California attorney general cannot begin until July 1, private plaintiffs have been able to bring claims under the law's limited private right of action since the beginning of the year. The CCPA is already having an impact on litigation.

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March 19, 2020

CCPA & COVID-19: A Practical Guide to Addressing Privacy and Data Security Implications of the Coronavirus

COVID-19 arrives just as the first omnibus privacy statute in the United States, the CCPA became effective. Since its January 1 effective date, we continue to wait for finalization of the CCPA regulations and enforcement that was slated for July 1.

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January 27, 2020

Washington, New York, and Minnesota Introduce New Privacy Laws to Begin the New Year

It's a new year and it looks like 2021 is going to be another eventful one for privacy. In the past few weeks, we've seen several states introduce new privacy legislation, starting with Washington.

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January 15, 2020

Business Solutions for CCPA Compliance

The California Consumer Privacy Act of 2018 (CCPA) is a sweeping new privacy statute that grants rights to consumers and imposes corresponding obligations on subject businesses.

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September 20, 2019

CCPA Amendments Provide Important Clarification

On Friday the 13th of September 2019—the last day of California's Legislative Session—California lawmakers updated, finalized and sent six bills that would amend the California Consumer Privacy Act (CCPA) to Governor Newsom's desk for signature. Despite months of efforts from various groups, the CCPA made it through the legislative session with relatively fewer changes than expected. This up

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August 6, 2019

CCPA 12-Month Compliance Series Part 6: Retaining and Deleting Data

The CCPA grants consumers the right to request deletion of any personal information which a business has collected from the consumer. Cal. Civ. Code § 1798.105. It also requires a business to fulfill deletion requests, and to direct service providers to do the same, within 45 days of receiving a "verified" or "verifiable" request from the consumer. Cal. Civ.

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July 9, 2019

Compliance Challenges for Brick-and-Mortars Under the CCPA

As we approach the California Consumer Privacy Act's (CCPA) effective date of January 1, 2020, brick-and-mortar businesses that increasingly engage with consumers online will have to begin their compliance efforts.

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June 24, 2019

Pseudonymized Personal Information on Blockchain Not Sufficient Under CCPA

The California Consumer Privacy Act (CCPA) imposes new transparency and disclosure obligations on businesses' use, sale, and disclosure of consumer information. Businesses will need to honor requests from consumers to access their personal information, delete their personal information, and opt out of the sale of their personal information.

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June 11, 2019

CCPA 12-Month Compliance Series Part 5: Responding to Consumer Requests

At the core of complying with the CCPA is knowing how to deal with consumer's requests with respect to any of the eight rights regarding their personal information (PI), which are:

An abbreviated right to disclosure regarding PI collected (§1798.100)
An expanded right to disclosure regarding PI collected (§1798.110(a))
Right to disclosure regarding PI sold or discl

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May 30, 2019

I Am Robot: California’s New Law Requires Disclosure of Use of Bots

Does your company use chatbots to interact with customers online? If so, California's new Autobot Law, Cal. Bus. & Prof. Code § 17940, et seq. (SB 1001) goes into effect July 1, 2019 and may affect your business.

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May 8, 2019

CCPA 12-Month Compliance Series Part 4: Update Your Privacy Policy

A business that is subject to the CCPA will need to update its consumer-facing online privacy policy.

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April 26, 2019

Promoting and Regulating Artificial Intelligence

It is no secret that artificial intelligence ("AI") is set to become the next wave in technological innovation.

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April 12, 2019

Takeaways from CA Senate Judiciary Hearing on Bill That Would Expand CCPA’s Private Right of Action

On April 9, 2019, the California Senate Judiciary committee voted to advance SB 561, which wo