An Analysis of the Requirement to Verify Consumer Requests and Parental Consents

On October 10, 2019, California Attorney General Xavier Becerra announced a long-awaited notice of proposed rulemaking and draft regulations for the California Consumer Privacy Act (CCPA), California’s new consumer privacy law, which we have analyzed here and here.

In parts one and two of our multi-part series regarding the draft CCPA regulations, we focused on businesses’ notice obligations and handling consumer requests.

In this third part of our series, we focus on proposed regulations regarding “verifiable” consumer requests, including the standards for verifying different types of requests received from consumers. As discussed below, the proposed CCPA regulations provide detailed guidance that will have important ramifications for businesses that possess or process consumer information.

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