Last week the California Privacy Protection Agency (“CPPA”) held its sixth Board meeting and first meeting of 2022.  The meeting notably included a discussion of the expected timing for issuing final regulations implementing the California Privacy Rights Act.

As a reminder, the Agency gave notice to the California Attorney General on October 21, 2021 that it was prepared to assume rulemaking authority.  As a result, rulemaking authority will transfer from the California Attorney General to the CPPA on April 21, 2022.  Executive Director Ashkan Soltani shared that the CPPA expects to complete its rulemaking in Q3 or Q4 of 2022.  The CPPA will hold virtual informational hearings with experts in mid-to-late March and public stakeholder hearings in April.  The staff and Board will then conduct formal rulemaking proceedings in Q2 (which requires publication of the proposed text of the regulations and a minimum of 45 days for public comment), with rulemaking to be completed in Q3 or Q4.  Although this means that the CPPA will not meet the July 1, 2022 statutory deadline for its rulemaking, the Executive Director noted that this schedule allows the CPPA to balance its continued work on CPPA staffing, while also undertaking substantial information gathering to inform the rulemaking.

Previous meetings have focused on the creation of the Agency and the initial work of Board Subcommittees focused on CPPA administration, public awareness, rulemaking process, and the creation of and updates to the rules.  The Board’s next meeting has not yet been scheduled.

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Photo of Lindsey Tonsager Lindsey Tonsager

Lindsey Tonsager helps national and multinational clients in a broad range of industries anticipate and effectively evaluate legal and reputational risks under federal and state data privacy and communications laws.

In addition to assisting clients engage strategically with the Federal Trade Commission, the…

Lindsey Tonsager helps national and multinational clients in a broad range of industries anticipate and effectively evaluate legal and reputational risks under federal and state data privacy and communications laws.

In addition to assisting clients engage strategically with the Federal Trade Commission, the U.S. Congress, and other federal and state regulators on a proactive basis, she has experience helping clients respond to informal investigations and enforcement actions, including by self-regulatory bodies such as the Digital Advertising Alliance and Children’s Advertising Review Unit.

Ms. Tonsager’s practice focuses on helping clients launch new products and services that implicate the laws governing the use of endorsements and testimonials in advertising and social media, the collection of personal information from children and students online, behavioral advertising, e-mail marketing, artificial intelligence the processing of “big data” in the Internet of Things, spectrum policy, online accessibility, compulsory copyright licensing, telecommunications and new technologies.

Ms. Tonsager also conducts privacy and data security diligence in complex corporate transactions and negotiates agreements with third-party service providers to ensure that robust protections are in place to avoid unauthorized access, use, or disclosure of customer data and other types of confidential information. She regularly assists clients in developing clear privacy disclosures and policies―including website and mobile app disclosures, terms of use, and internal social media and privacy-by-design programs.

Photo of Libbie Canter Libbie Canter

Libbie Canter represents a wide variety of multinational companies on privacy, cyber security, and technology transaction issues, including helping clients with their most complex privacy challenges and the development of governance frameworks and processes to comply with global privacy laws. She routinely supports…

Libbie Canter represents a wide variety of multinational companies on privacy, cyber security, and technology transaction issues, including helping clients with their most complex privacy challenges and the development of governance frameworks and processes to comply with global privacy laws. She routinely supports clients on their efforts to launch new products and services involving emerging technologies, and she has assisted dozens of clients with their efforts to prepare for and comply with federal and state privacy laws, including the California Consumer Privacy Act and California Privacy Rights Act.

Libbie represents clients across industries, but she also has deep expertise in advising clients in highly-regulated sectors, including financial services and digital health companies. She counsels these companies — and their technology and advertising partners — on how to address legacy regulatory issues and the cutting edge issues that have emerged with industry innovations and data collaborations.

Photo of Jayne Ponder Jayne Ponder

Jayne Ponder is an associate in the firm’s Washington, DC office and a member of the Data Privacy and Cybersecurity Practice Group. Jayne’s practice focuses on a broad range of privacy, data security, and technology issues. She provides ongoing privacy and data protection…

Jayne Ponder is an associate in the firm’s Washington, DC office and a member of the Data Privacy and Cybersecurity Practice Group. Jayne’s practice focuses on a broad range of privacy, data security, and technology issues. She provides ongoing privacy and data protection counsel to companies, including on topics related to privacy policies and data practices, the California Consumer Privacy Act, and cyber and data security incident response and preparedness.

Photo of Neelofer Shaikh Neelofer Shaikh

Neelofer Shaikh is an associate in the firm’s Los Angeles office and a member of the Data Privacy and Cybersecurity Practice Group.

Neelofer advises clients on a broad range of privacy and cybersecurity issues, including compliance obligations, cybersecurity incident preparedness and response, and…

Neelofer Shaikh is an associate in the firm’s Los Angeles office and a member of the Data Privacy and Cybersecurity Practice Group.

Neelofer advises clients on a broad range of privacy and cybersecurity issues, including compliance obligations, cybersecurity incident preparedness and response, and responses to regulatory inquiries.