Part 2 of BakerHostetler’s Countdown to CPRA – Top 5 FAQs to Evaluate Compliance Strategy for Employees

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In Part 1 of BakerHostetler’s Countdown to CPRA blog series, we provided initial guidance to businesses on key California Privacy Rights Act (CPRA) compliance readiness considerations. On January 1, 2023, California could become the first U.S. state to enact a comprehensive data privacy law covering employment-related data (“B2E”), whereas the California Consumer Privacy Act (CCPA) currently only applies to employment data in a limited fashion. While we continue to await final regulations from the California Privacy Protection Agency, which we have learned may be delayed until the third or fourth quarter of 2022, we continue to assess and provide guidance on key areas of focus for businesses to consider when developing a business strategy for CPRA compliance for B2E.

As we reported here, California legislators have recently proposed amendments extending exemptions affecting B2E and business-to-business data, which we will continue to monitor closely. Still, companies are well advised to press forward with compliance efforts under the assumption that the exemptions will expire, in order

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