In Part 1, see https://www.canada-usblog.com/2019/10/23/california-consumer-privacy-act-are-you-ready-part-1/, we summarized the recent legislative changes regarding the California Consumer Privacy Act (“CCPA”). Bearing in mind the CCPA takes effect on January 1, 2020 and the Attorney General is required to issue regulations by July 1, 2020, these regulations both meet that timeframe, but also seek to provide much-needed guidance

When the law was signed by then Governor Brown (see our prior Alert here), the expectation was that Attorney General Becerra would issue the enabling regulations by July of this year, which would allow a phase-in period. Then by January 1, 2020, the requirements would be clear and companies would be able to properly