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CCPA Compliance Reminder: Annual Update Requirement for Online Privacy Policies

For businesses subject to the California Consumer Privacy Act (CCPA), a compliance step often overlooked is the requirement to annually update the businesses online privacy policy. Under Cal. Civ. Code § 1798.130(a)(5), CCPA-covered businesses must among other things update their online privacy policies  at least once every 12 months . Note that CCPA regulations establish content requirements for online privacy policies, one of which is that the policy must include “the date the privacy policy was last updated.” See 11 CCR § 7011(e)(4). As businesses continue to grow, evolve, adopt new technologies, or otherwise make online and offline changes in their business, practices, and/or operations, CCPA required privacy policies may no longer accurately or completely reflect the collection and processing of personal information. Consider, for example, the adoption of emerging technologies, such as so-called “artificial intelligence” tools. These tools may be collecting, inferring, or pro...

July Is the New January – 2025 (Maryland)

  States and cities are as busy as ever passing new workplace regulations throughout the calendar year. Here is our mid-year report summarizing the notable labor and employment laws that take effect from roughly July through October.  Maryland Bill / Ordinance / Regulation Main Topic Summary Effective Date Maryland HB 1108   Retail Alters the minimum age for employment in Allegany County with certain alcoholic beverages license holders from 16 to 18 years of age. 7/1/2025 Maryland HB 567 (SB541)   Privacy and Data Security Establishes the Maryland Online Data Privacy Act of 2024; requires businesses that collect personal data to conduct a regular assessment of activities that present a heightened risk of harm to consumers, including automated decisions and algorithms. 10/1/2025 Maryland HB 776 (SB423)   Healthcare Requires healthcare employers to notify the state when suspending, terminating, or accepting a voluntary resignation from a licensed physician for rea...