CCPA Is Here, And It Does Have Requirements For Employees, Applicants, etc.


Some business leaders and HR professionals may be waking up this morning not realizing they must provide a “Notice at Collection” to some or all of their employees and applicants under the new California Consumer Privacy Act (CCPA). This is not surprising given the confusion during 2019 about whether this law would reach that far. The passage of AB 25 confirmed that while employees would be temporarily excluded from most of the CCPA’s protections, two areas of compliance remain: (i) providing a notice at collection, and (ii) maintaining reasonable safeguards for personal information driven by a private right of action now permissible for individuals affected by a data breach caused by a business’ failure to do so.