California is imposing tough new rules on processing the data of anyone under the age of 18, with the potential to affect businesses that don't target younger consumers.
The California Privacy Protection Agency (CPPA) is still going strong in its effort to ramp up enforcement of the California Consumer Privacy Act and protect the rights of state residents. In July 2023, the Agency unveiled a new consumer complaint tool that is available on its website.
The new complaint form will significantly streamline the process for consumers, and give them a direct line of communication to the first-of-its-kind Agency. In the first few days the tool was available online, before it was even announced to the public, the Agency had already received over a dozen complaints. This signals a strong interest among California residents for a way to hold businesses accountable for their lack of CCPA compliance.
Expectations have always been that, as the CPPA takes over its role as the primary enforcer of the CCPA, enforcement activity will pick up at a rapid pace. While at this point (writing in July 2023, when the Agency’s authority has just become official) we haven’t yet seen any new investigations made public, there is still plenty of evidence to back up those expectations.
The Agency has been on a hiring blitz, bringing on new attorneys, auditors, and technology experts. Among these new hires is a Deputy Director of Enforcement, who recently laid out his vision for the future, including enforcement priorities, and who has made clear that he looks forward to vigorously enforcing California’s privacy law.
The new complaint tool fits into this overall trend. With 1000s of businesses covered by the CCPA, the online form lets the Agency essentially crowdsource the search for noncompliant businesses. Just as importantly, the system will also compel the Agency to act in many cases. That’s because, if it receives a sworn complaint, the Agency must contact the complainant to explain any action it took or failed to take in response to their complaint. This will leave the Agency with little choice but to investigate those complaints.
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