Understanding the CCPA Proposed Regulations: Summary and Analysis

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California State Attorney General Xavier Becerra issued the much-anticipated proposed regulations to implement the California Consumer Privacy Act (CCPA).

The CCPA applies to all industries and to all entities that meet the definition of a “business” under the CCPA. That means credit unions and Credit Union Service Organizations (CUSOs) that meet the definition of a business may be:

1) Required to comply with some, or all, of the CCPA’s provisions even though some personal information is exempted under the California Financial Information Privacy Act (CFIPA) and the Gramm-Leach-Bliley Act (GLBA).

2) Liable under the CCPA for a data breach of ANY non-encrypted and non-redacted personal information, including information collected under the scope of the CFIPA and GLBA.

The California and Nevada Credit Union Leagues have reviewed the proposed regulations to effectively address them on behalf of credit unions and their members across both states, and to provide you with a detailed summary of the regulations, as well as an analysis outlining observations and concerns that we have identified with the proposed regulations.

On the same day the attorney general issued the proposed regulations, California Governor Gavin Newsom also signed six amendments to the statute. Click here to view the PolicyWorks bulletin regarding the CCPA amendments.

In addition to the above resources, the Leagues are offering a recorded webinar: CCPA—Preparing for The Next Generation of Data Protection. This webinar will be available on Monday, Nov. 25. Click here for more information and to register.

The Leagues urge all credit unions to review the above resources and comment on the proposed regulations via PowerComment by the comment deadline of 5 p.m. on Dec. 6, 2019.

You can also voice your concerns on the proposed regulations at any of the attorney general’s four public hearings. Information on the public hearings is available here.

League Resources (click each):

If you have any questions, please contact Sharon Turley, vice president of regulatory advocacy for the Leagues.

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