CA Proposes Third Set of Modifications to CCPA Regulations

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The California Department of Justice has provided notice of a third set of proposed modifications to California Consumer Privacy Act (CCPA) regulations.

These proposed modifications focus on provisions concerning the notice of the right to opt-out, requests to opt-out, and the use of authorized agents for making requests. Specifically, they include the following changes: 

  • Proposed section 999.306, subd. (b)(3) — Provides examples of how businesses that collect personal information in the course of interacting with consumers offline can provide the notice of right to opt-out of the sale of personal information through an offline method.

  • Proposed section 999.315, subd. (h) — Provides guidance on how a business’s methods for submitting requests to opt-out should be easy and require minimal steps.  It provides illustrative examples of methods designed with the purpose or substantial effect of subverting or impairing a consumer’s choice to opt-out.

  • Proposed section 999.326, subd. (a) — Clarifies the proof that a business may require an authorized agent to provide, as well as what the business may require a consumer to do to verify their request.

  • Proposed section 999.332, subd. (a) — Clarifies that businesses subject to either section 999.330, section 999.331, or both of these sections are required to include a description of the processes set forth in those sections in their privacy policies.

These modifications are indicated by bold blue underline for proposed additions and red strike-out for proposed deletions to the regulations that became effective on Aug. 14, 2020 within the Comparison Version of the Third Set of Proposed Modifications.

This notice, the text of the third set of proposed modifications to the regulations, and a comparison of the text as approved by the Office of Administrative Law with the currently proposed modifications are available here.

The department will accept written comments regarding the proposed changes between Oct. 13, 2020 and Oct. 28, 2020. All written comments on the underlined changes must be submitted to the department no later than 5 p.m. on Oct. 28, 2020. You can email

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