California's new data privacy law - the California Consumer Privacy Act of 2018 ("CCPA") - will go into effect on January 1, 2020.
The CCPA obligations will affect applicable financial institutions that navigated the implementation of the EU's General Data Protection Regulation ("GDPR"). Many of the systems and processes designed for GDPR compliance will satisfy the CCPA requirements. Financial institutions should note that between now and January 1, 2020, additional U.S. federal and state laws and regulations on data protection may evolve and expand.
As explained more fully in a Cadwalader memorandum, here are some key takeaways concerning the CCPA: