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Hello all, and happy Thursday!  

Remember back in early July when we reported on the delay of CPRA enforcement? If you’ll recall, California Superior Court Judge James Arguelles ruled that because the California Privacy Protection Agency (CPPA) didn’t issue its CPRA regulations until March of 2023, then enforcement ought to be delayed correspondingly. So, rather than begin on July 1, 2023, CPRA enforcement would start March 29th, 2024 instead.  

At the time, we warned that this would not mean that all enforcement would be delayed until 2024. That certainly appears to be the case. CPPA Executive Director Ashkan Soltani stated that “significant portions” of the CCPA’s privacy protections could be enforced starting July 1. 

The CPPA Deputy Director of Enforcement, Michael Macko, said, “There’s no vacation here from enforcement. When we find violations, we will take aggressive action to protect the public.” 

The California Attorney General’s Office is in the midst of an investigative sweep of companies’ compliance in regard to employee data. Meanwhile, the CPPA is investigating data collected by connected cars. 

If you were hoping that the delay in CPRA enforcement meant you could put compliance off for another year, no dice. Clearly, the California Attorney General and CPPA intend to enforce as much of the law as they are permitted to. As for those portions that have been delayed, the CPPA and Attorney General have filed a petition to overturn Judge Arguelles’s decision. 

Best, 

Arlo 

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