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Perkins on Privacy

Perkins on Privacy keeps you informed about the latest developments in privacy and data security law. Our insights are provided by Perkins Coie's Privacy & Security practice, recognized by Chambers as a leading firm in the field. Subscribe 🡢

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China’s New Personal Information Protection Specifications

After undergoing several rounds of revisions to the 2019 draft specifications, the new Information Security Technology-Personal Information Security Specifications (GB/T35273-2020) (New Personal Information Specifications) were released jointly by the State Administration of Market Regulation and the Standardization Administration of China on March 6, 2020.

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In a Surprise Move, the Brazilian Landmark Privacy Law, LGPD, Is About to Be in Effect

In the latest chapter of the discussions about Brazil's LGPD, on August 26, 2020, the Senate rejected the article in the Executive Order ('Medida Provisória' – MP) which provided for the extension of its implementation to May 3, 2021. Accordingly, the MP will lose effect in relation to that article, and the LGPD will go into force promptly, pending only the presidential sanction.

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The AG Publishes Its FAQs on the CCPA

The attorney general's office has posted a set of FAQs and corresponding responses on its California Consumer Privacy Act (CCPA) site. While aimed at providing guidance to consumers about the CCPA, the FAQs can also serve as a quick reference for businesses regarding their CCPA compliance obligations.

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CCPA Compliance: Financial Incentives Requirements

The California Consumer Privacy Act of 2018 (CCPA) regulates a company's offerings of financial incentives and price or service differences related to the collection, retention, or sale of personal information. Cal. Civ. Code Section 1798.125(a)(2); Final Text of CCPA Regulations, 999.301(j), 999.307, 999.336.

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CCPA in Litigation: 2018 to Present

The California Consumer Privacy Act (CCPA) went into effect three months ago, on January 1, 2020. Although enforcement by the California attorney general cannot begin until July 1, private plaintiffs have been able to bring claims under the law's limited private right of action since the beginning of the year. The CCPA is already having an impact on litigation.

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CCPA & COVID-19: A Practical Guide to Addressing Privacy and Data Security Implications of the Coronavirus

COVID-19 arrives just as the first omnibus privacy statute in the United States, the CCPA became effective. Since its January 1 effective date, we continue to wait for finalization of the CCPA regulations and enforcement that was slated for July 1.

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Washington, New York, and Minnesota Introduce New Privacy Laws to Begin the New Year

It's a new year and it looks like 2021 is going to be another eventful one for privacy. In the past few weeks, we've seen several states introduce new privacy legislation, starting with Washington.

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Business Solutions for CCPA Compliance

The California Consumer Privacy Act of 2018 (CCPA) is a sweeping new privacy statute that grants rights to consumers and imposes corresponding obligations on subject businesses.

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CCPA Amendments Provide Important Clarification

On Friday the 13th of September 2019—the last day of California's Legislative Session—California lawmakers updated, finalized and sent six bills that would amend the California Consumer Privacy Act (CCPA) to Governor Newsom's desk for signature. Despite months of efforts from various groups, the CCPA made it through the legislative session with relatively fewer changes than expected. This up

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CCPA 12-Month Compliance Series Part 6: Retaining and Deleting Data

The CCPA grants consumers the right to request deletion of any personal information which a business has collected from the consumer. Cal. Civ. Code § 1798.105. It also requires a business to fulfill deletion requests, and to direct service providers to do the same, within 45 days of receiving a "verified" or "verifiable" request from the consumer. Cal. Civ.

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Compliance Challenges for Brick-and-Mortars Under the CCPA

As we approach the California Consumer Privacy Act's (CCPA) effective date of January 1, 2020, brick-and-mortar businesses that increasingly engage with consumers online will have to begin their compliance efforts.

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Pseudonymized Personal Information on Blockchain Not Sufficient Under CCPA

The California Consumer Privacy Act (CCPA) imposes new transparency and disclosure obligations on businesses' use, sale, and disclosure of consumer information. Businesses will need to honor requests from consumers to access their personal information, delete their personal information, and opt out of the sale of their personal information.

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CCPA 12-Month Compliance Series Part 5: Responding to Consumer Requests

At the core of complying with the CCPA is knowing how to deal with consumer's requests with respect to any of the eight rights regarding their personal information (PI), which are:

An abbreviated right to disclosure regarding PI collected (§1798.100)
An expanded right to disclosure regarding PI collected (§1798.110(a))
Right to disclosure regarding PI sold or discl

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I Am Robot: California’s New Law Requires Disclosure of Use of Bots

Does your company use chatbots to interact with customers online? If so, California's new Autobot Law, Cal. Bus. & Prof. Code § 17940, et seq. (SB 1001) goes into effect July 1, 2019 and may affect your business.

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CCPA 12-Month Compliance Series Part 4: Update Your Privacy Policy

A business that is subject to the CCPA will need to update its consumer-facing online privacy policy.