CCPA Update: Extending Deadlines for Employees and Personnel of Other Businesses

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Employees, Directors, and Owners

The CCPA (California Consumer Privacy Act) has a temporary exemption for the persons described below. Under this exemption, most requirements of the CCPA do not apply to Personal Information that is:

  • Collected by a Business about the personnel associated with that Business if the Personal Information is collected and used by the Business solely within the context of the natural person’s role with the Business;
  • Collected by a business that is emergency contact information of the Business’ personnel to the extent that the personal information is collected and used solely within the context of having an emergency contact on file; and
  • Necessary for a Business to retain or administer benefits for personnel of the Business to the extent that the Personal Information is collected and used solely within the context of administering those benefits.

“Personnel” includes job applicants, employees, officers, contractors, directors, medical staff members, persons who own 50% or more of the Business, persons who control the election of a majority of the board of directors of the Business, and persons who exercise a controlling influence over management.

This temporary exemption does not apply to:

  • The Business’ obligation to inform a person about categories of Personal Information collected and the purposes for which the Personal Information is used (“Collection Notice”),
  • The Consumer’s right to request that the Business delete the Consumer’s PI, or
  • A Business’ liability for damages from a data breach.

This temporary exemption ends on January 1, 2021. A proposed bill, AB 1281, would extend this temporary exemption until January 1, 2022.

Business to Business Transactions

The CCPA also has a temporary exemption for the additional persons described below.

Under this exemption, the requirements of the CCPA do not apply to Personal Information of personnel of another business or entity that is received by a Business when:

  • Providing goods & services to the entity,
  • Receiving goods & services from the entity, or
  • Performing due diligence of the entity.

“Personnel” includes job applicants, employees, officers, contractors, directors, medical staff members, persons who own 50% or more of the Business, persons who control the election of a majority of the board of directors of the Business, and persons who exercise a controlling influence over management.

This temporary exemption ends on January 1, 2021. AB 1281 would also extend this temporary exemption until January 1, 2022.

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