February 2022: CCPA/CPRA Reminder of Training Deadline

Update Applicable to:
All employers covered by the California Consumer Privacy Act (CCPA)/California Privacy Rights Act (CPRA) in the state of California

What happened?
This is a reminder of a deadline for the California Code of Regulations Title 11, Section 999.317 under the CCPA and CPRA.

What are the details?
All businesses covered by the CCPA/CPRA must identify any employee who may receive an inquiry from a consumer regarding the business’s privacy practices and train those employees. Covered businesses include those that meet at least one of the following requirements:

• Making more than $25 million annually.
• Collecting personal information of 50,000 or more California residents under CCPA in effect today, or 100,000 or more California residents when CPRA goes into effect on January 1, 2023; or
• Deriving 50 percent or more of their revenue from the sale/sharing of California residents’ personal information.

To comply with the law, training must include:

• Consumer rights under the CCPA/CPRA;
• How consumers can exercise those rights; and
• The business’s responsibility in responding to those inquiries/rights.

CCPA/CPRA provisions will be enforced by the newly created California Privacy Protection Agency. Businesses covered by the CCPA/CPRA should make sure they’re complying with the consumer rights provided by these laws and that their employees who may receive an inquiry are properly trained by the compliance deadline of January 1, 2023.

For more information, please see the links below:

California Consumer Privacy Act (CCPA)

Article 1 – Article 2

What do employers need to do? Employers should review the links provided above, monitor CCPA/CPRA activity, update the training required for staff responsible for handling consumer rights requests to reflect the CPRA changes and review the adequacy of the business’s safeguards to protect personal information.