Summer 2019 Defense Comment 5 Continued on page 6 Don Willenburg, Gordon Rees Scully Mansukhani Alexander Golovets, Law Offices of Alexander Golovets The California Consumer Privacy Act of 2018 ("CCPA") The California Consumer Privacy Act of 2018 (“CCPA”) (full text https://leginfo.legislature. id=201720180SB1121) becomes effective January 1, 2020. It affects even those who do not share or sell consumer information. Your law firm, and many business clients of your firm, may need to implement procedures to comply with the CCPA, particularly the requirements to respond to requests to disclose or delete personal information, to create procedures to do so, and to train employees how to respond. describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” The CCPA lists eleven nonexclusive categories of such information, including name, address (IP, email, or postal), driver’s license number, social security number, passport information, records of purchases, and “consuming history and tendencies.” The CCPA applies to information collected or stored electronically, but it is not limited to electronic information. It covers paper files too. The CCPA was enacted quickly, under the threat of an even more restrictive ballot initiative (which was withdrawn upon enactment). That haste may be at least partly to blame for its many ambiguities and inconsistencies. This is a big deal, and you are probably not ready. Get ready, and get ahead of the curve to get your clients ready. WHAT,ANDWHOSE,“PERSONAL INFORMATION” IS COVERED? The CCPA governs use of “personal information,” which it broadly defines as “information that identifies, relates to,