ARTICLE
29 April 2019

Will CCPA's Definition Of Consumer Be Narrowed?

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Sheppard, Mullin, Richter & Hampton LLP

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In response to the concern of many that the definition of consumer is so broad as to cover employees, a bill has been introduced in California to exclude employees from the scope of CCPA.
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In response to the concern of many that the definition of consumer is so broad as to cover employees, a bill has been introduced in California to exclude employees from the scope of CCPA. As those who have been following CCPA are aware, the definition of "consumer" is extremely broad. Under the proposal, amended on March 25 of this year, the definition would specifically exclude from the definition information collected by a business "in the course of a person acting as a job applicant," employee, contractor, or agent of the business. The carve-out goes on to clarify that this would hold true only if the individual's information is used "for purposes compatible with the context" in which they gave it to the company.

Putting it Into Practice: We are continuing to monitor this and other developments of CCPA.

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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