1. What’s changing?
Under the current version of the California Consumer Privacy Act (“CCPA”), an employer’s obligations related to the personal information it collects from employees, applicants, and contractors residing in California (collectively, “Employment Information”) are relatively limited. Specifically, it needs to (1) provide those individuals a “notice at collection” that discloses the categories of personal information the employer collects about them and the purposes for which that information is used, and (2) safeguard those individuals’ personal information against unauthorized access or acquisition.
Come January 1, 2023, however, those obligations will dramatically expand when California’s new comprehensive privacy law, the California Privacy Rights Act (“CPRA”), which amends the CCPA, takes effect.
2. How will Employment Information be treated after January 1, 2023?
Subject to any regulatory updates, Employment Information will be treated like commercial consumer information.
3. What are we required to do by January 1, 2023?
With respect to Employment Information, the core requirements of the CCPA will be as follows:
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