When covered businesses collect personal information about employees and job applicants, the California Consumer Privacy Act (CCPA) requires them to comply with certain disclosure obligations.
Covered businesses need to prepare for major changes to the law, which were approved by California voters under Prop 24's California Privacy Rights Act (CPRA). Most notably, a CCPA exception for employee and job applicant data will end on Jan. 1, 2023 and provide employees and applicants with the same CCPA rights that have applied to consumers since 2020.
The CPRA also will add new rights. Employers should be keenly aware of their obligations under the CCPA and CPRA, as litigation and enforcement actions are likely to increase, and the deadline to comply is fast approaching.
With so many requirements to review, you may have missed a lesser known, but important, obligation to provide sufficient training to everyone who is responsible for your CCPA and CPRA compliance measures, or for handling consumer inquiries about your privacy practices.
What Are the Current Training Requirements?
Under the CCPA, which took effect on Jan. 1, 2020, covered businesses must ensure that all individuals responsible for the business's compliance with the CCPA or handling the business's response to consumer inquiries about privacy practices are informed of all applicable CCPA requirements. This includes knowing how to direct consumers to exercise their rights under the CCPA.
The CCPA regulations contain...
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