by Jeffrey P. Cunard, Luke Dembosky, Jeremy Feigelson, Avi Gesser, Jim Pastore, Javier Alvarez-Oviedo, Jeremy C. Beutler, H Jacqueline Brehmer, Christopher S. Ford, and Kate Saba

On Friday evening, February 7, the California Attorney General released a new round of proposed changes to the draft regulations implementing the California Consumer Privacy Act. Some thoughts to help guide interested parties through the AG’s dense 32-page release (PDF: 1.25 MB), which redlines the proposed modifications against the prior draft regulations:

Guidance on “Personal Information”

The draft proposes to clarify the definition of “personal information,” which turns on whether the information can be associated or linked with a particular consumer or household. It then provides an example: “[I]f a business collects the IP addresses of visitors to its website but does not link the IP address to any particular consumer or household, and could not reasonably link the IP address with a particular consumer or household, then the IP address would not be ‘personal information.’” Continue reading →