The new draft of the CPRA regulations makes it clear that businesses can't just ignore them until they are final - good faith efforts to comply with the regulations will be looked at favorably. Businesses should make every effort to comply with the regulations as written, but should be prepared to adjust course as the regulations are revised. This should also apply to efforts to comply with areas of the CPRA that don't have regulations, such as how to comply for employment and business-to-business information.
As part of the Agency's decision to pursue investigations of possible or alleged violations of the CCPA, the Agency may consider all facts it determines to be relevant, including the amount of time between the effective date of the statutory or regulatory requirement(s) and the possible or alleged violation(s) of those requirements, and good faith efforts to comply with those requirements.
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