ARTICLE
21 July 2025

Big Privacy Moves Coming Out Of California. Are You Ready?

TC
Thompson Coburn LLP

Contributor

For almost 100 years, Thompson Coburn LLP has provided the quality legal services and counsel our clients demand to achieve their most critical business goals. With more than 400 lawyers and 50 practice areas, we serve clients throughout the United States and beyond.
At IAPP GPS 2024, CPPA Executive Director Tom Kemp gave a clear message: the agency is shifting into high gear—expanding its regulatory scope and sharpening its enforcement focus.
United States Intellectual Property

At IAPP GPS 2024, CPPA Executive Director Tom Kemp gave a clear message: the agency is shifting into high gear—expanding its regulatory scope and sharpening its enforcement focus.

🔍 Here's what to watch:

🛠️ New rules coming:

The CPPA is preparing to finalize regulations on automated decision-making (ADMT), cybersecurity audits, and implementation of the Delete Act—which includes a new portal (DROP) allowing Californians to request deletion of their data from all registered data brokers.

⚖️ More enforcement, more clarity: The agency is increasing enforcement and intends to "telegraph" its priorities. Watch for guidance on core CCPA rights like access, deletion, and data minimization. The soft launch is over.

📊 Internal audit power: CPPA is hiring a chief auditor and investigators to operationalize annual cybersecurity audits—a CPRA requirement with EU-style accountability.

🤖 AI rules coming fast: Upcoming ADMT rules include opt-out rights for personal-information-based AI systems. While generative AI may see carve-outs, the CPPA is laser-focused on how personal data powers automated decision-making. As Kemp put it, the goal is "guardrails, not brakes."

💰 And yes—it'll be expensive: Governor Newsom's office has projected a $3.5B cost in year one alone to implement new automation rules. But for many businesses, non-compliance will cost more.

✅ What it means for your privacy program:

  • Get involved in the rulemaking process this summer
  • Budget and plan for audit-readiness
  • Monitor ADMT definitions and opt-out requirements
  • Prepare for a more assertive enforcement landscape

California isn't slowing down. Are you keeping up?

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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