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Hello all, and happy Thursday!  

On February 9th, the California Privacy Protection Agency (CPPA) made a(nother) surprise announcement. It won its appeal and CPRA enforcement is effective now—not as of March 29, 2024, but as of July 1, 2023. 

For those of you who haven’t been following the shifting timeline of CPRA enforcement, here’s a quick (but admittedly complicated) overview. 

Most of the CPRA came into force on January 1, 2023. However, only the statutory requirements of the CPRA and the regulatory requirements of the previous California Consumer Privacy Act (CCPA) were enforceable; that is, those requirements defined in the text of the law itself and the regulations developed around the earlier CCPA. 

Some issues (like data privacy) are too expansive and complicated to effectively manage with just one fixed set of requirements defined in the text of a law. In these cases, another state or federal authority makes rules that comprise the law’s regulatory requirements. In regard to the CPRA, that authority is the CPPA. This agency has been making additional rules to ensure the CPRA comprehensively and effectively regulates data privacy in California.  

 Unfortunately, the CPPA was late finalizing its rules and only wrapped them up in March of 2023. The California Chamber of Commerce sued, arguing that enforceability was always meant to kick in a year after rulemaking was finalized, so California courts delayed enforcement to March 29th, 2024. The CPPA filed an appeal at the time. 

 Again, this refers to the regulatory enforcement of the CPRA; not the statutory enforcement of the CPRA or the regulatory enforcement of the CCPA. That’s why the Sephora enforcement action could take place, even though CPRA enforcement hadn’t fully kicked in. Enforcement of the additional requirements developed by the CPPA had been delayed until March 29th, 2024. Until recently, that is. 

We were all geared up for the CPRA to finally be fully enforceable in all respects as of March 29th, but California's Third District Court of Appeal threw us for a loop and granted the CPPA’s appeal. As a result, not only is the CPRA enforceable as of today, but it has been enforceable as of July 1, 2023—the original date when enforcement was meant to kick in. 

Okay. That’s a lot of nitty-gritty about the legislative process, lawmaking, and court systems (not to mention a lot of acronyms that start with the letter C).  

The big picture is this: The CPRA is in full effect now! The best time to become compliant with California’s privacy law was yesterday; the second best time is today. 



P.S. It’s your last chance to register for Osano and KPMG’s webinar on data mapping! If you’ve seen this in time, the webinar is happening TODAY at 1 PM EST. Register on the IAPP’s website here 

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If you’re interested in working at Osano, check out our Careers page! Right now, we’re looking for a Lead Privacy Architect—check out the job description here to see if you’d be a good fit.

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