“Notice at Collection” and Privacy Policy Requirements Under the CPPA’s Draft Regulations

Among the many details to absorb in the draft amendments to the CCPA regulations published by the California Privacy Protection Agency (“CPPA”) on May 27 (the ​“Draft Regulations”) are new and prescriptive disclosure requirements for notices at collection and privacy policies. While these disclosure provisions (and all of the other provisions of the Draft Regulations) are subject to further changes, it is important that businesses begin to assess carefully these provisions and devise strategies for operationalizing compliance with them, especially since disclosures provide some of the most visible signals of CCPA compliance.