Date: July 13, 2023
The privacy protections afforded by the California Consumer Privacy Act (CCPA) extend not only to traditional consumers but also to employees, job applicants, contractors and human resources professionals. The regulations have been finalized and, while enforcement of the California Privacy Rights Act (CPRA) is delayed until March 2024, employers should get ready now for this important milestone.
Join privacy Partner Katy Linsky and employment Associate Laurie Baddon for a robust discussion and practical tips to prepare for CPRA enforcement in the employment context. Discussion topics include:
- Understanding the enforcement landscape and penalties
- Scoping CCPA applicability, conducting a “data discovery” exercise (including both structured and unstructured data sources) and developing a risk-based plan to tackle compliance obligations
- Updating or developing key documents, including privacy notices, contracts with vendors and other data recipients, and employment policies and handbooks, etc.
- Developing processes to receive and honor GDPR-like data subject rights from employees, applicants and business contacts (including rights to access, correct and delete)
- Evaluating whether common HR activities constitute a “sale” or “financial incentive” that triggers more complicated compliance obligations
- Implementing other important process requirements, such as training, security and privacy impact assessment