Counting Down to 2023: CPRA Template Available
The California Privacy Rights Act (CPRA) that amended California’s Consumer Privacy Act (CPPA) comes fully into force on January 1, 2023 and the California Privacy Protection Agency is supposed to start enforcing the CPRA on July 1, 2023.
Covered employers should spend sufficient time at the end of 2022 to prepare for compliance. Attached is a sample template Notice that employers may review to help move that process forward. Please note that any notice should be customized for an employer’s specific business and there is no “one size fits all” notice provision.
So, employers covered by the CPRA/CPPA should work with counsel to customize a unique notice to ensure that proper notice is provided to their California workforce and applicants. A “data mapping” exercise may be warranted to identify the full range of Personal Information or Sensitive Personal Information that the Company maintained, for which purposes and how long such information is maintained so that a company’s policies adequately and accurately reflect the correct information. This, too, may be developed with counsel to best protect a California employer.
California employers should contact Dan M. Forman, Dalia Khatib or Linda Wang or their favorite CDF attorney as soon as practical as the clock counts down to customize their notice. In addition, CDF’s Privacy Team has template policies that may be customized to insert into employee handbooks to protect the company during this evolving area of California law. We are also happy to advise on any of the other myriad changes to California’s employment laws that go into effect in the New Year.