California’s Proposition 24 passed as expected, and the new California Privacy Rights Act will change the privacy landscape created by the California Consumer Protection Act (CCPA), which went into effect only months ago. While the CPRA won’t go into effect until Jan. 1, 2023, with enforcement (concerning data collected from Jan. 1, 2022 and later) beginning no sooner than July 1, businesses should already be in a position to comply.

In short, the difficult work in marshaling the data subject to the CPRA will need to have been undertaken in connection with CCPA compliance. As such, assuming a business has taken efforts to comply with the CCPA, the new law will require evolution rather than revolution of companies’ privacy practices. That does not mean, however, there is not work to be done, and companies subject to the CPRA should be taking steps to comply sooner rather than later.

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