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Will CCPA Enforcement be Delayed?

Cyber Law and Data Protection Alert | March 20, 2020
By: Joshua A. Mooney, Richard M. Borden and Gwenn B. Barney

Over thirty organizations sent a letter to California state Attorney General Xavier Becerra this week arguing that the lawmaker should delay enforcement of actions under the California Consumer Protection Act (CCPA) in light of the COVID-19 outbreak.

CCPA, a state data privacy law that allows consumers to learn what personal information businesses hold about the consumer, request deletion of that information, and opt out of their information’s sale, among other rights, went into effect January 1, 2020, but enforcement actions are not set to begin until July 1.

In the letter, the coalition of signees, which includes the Association of National Advertisers, UPS, the California Chamber of Commerce, and the Internet Coalition, explained they “are concerned that given current events and the presently unfinished status of the regulations implementing the CCPA, businesses will not have the operational capacity or time to bring their systems into compliance with the final regulatory requirements by July 1, 2020.” California regulators are still fleshing out the details of the law, having provided a second set of revised draft regulations on March 11, 2020.

The coalition asked that enforcement be postponed until January 2, 2021. If granted, a delay in enforcement would present companies with time to address meeting the requirements of CCPA under the new operational conditions imposed by the COVID-19 pandemic event.

If you have questions or would like further information, please contact Joshua Mooney (; 215.864.6345) or Richard Borden (; 212.631.4439), or Gwenn Barney (; 215.864.7063).

As we continue to monitor the novel coronavirus (COVID-19), White and Williams lawyers are working collaboratively to stay current on developments and counsel clients through the various legal and business issues that may arise across a variety of sectors. Read all of the updates here.

This correspondence should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult a lawyer concerning your own situation and legal questions.
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