top of page

A New Year Brings New U.S. Privacy Regulations: The California Consumer Privacy Act (CCPA) Starts 1

The California Consumer Privacy Act (CCPA) goes partially into effect on January 1, 2020 and may impact your business. Reyes & Schroeder Associates, P.C. can assist you with your compliance obligations. What is the CCPA?

The CCPA is the first US-based privacy law that applies across industries, imposing privacy and security requirements for organizations handling California consumer data; including employee data. The CCPA establishes business obligations and grants consumer rights over personal information. You may have to comply with this law if you are a for-profit business and collect and process personal information related to California residents, including employees; and

  1. Have annual gross revenues over $25,000,000; or

  2. Annually buy, receive, sell or share for commercial purposes, alone or in combination, the personal information of 50,000 or more California consumers, households or devices; or

  3. Derive 50 percent or more of your annual revenues from selling consumers’ personal information.


If you are considered a covered business under the CCPA and have California resident employees, you will be required to (i) disclose to employees, applicants and certain others the categories of their personal information that you collect and process and (ii) the purposes for using such information. You must create or update your public-facing and internal-facing employment related privacy policy to include the required disclosure. This is the obligation of the employer, regardless of the involvement of a service provider to process your employee data.

Temporary Exemption for Employment Data

On September 13, 2019, the California legislature adopted Assembly Bill 25 (AB 25) to provide a one-year delay in the application of the CCPA to employers and employment records, for most of the requirements under the CCPA. This amendment was signed by the California Governor on October 11, 2019. The employee data exemption under AB 25 is temporary and is set to expire on January 1, 2021, unless extended.

Employer Obligations under the AB 25 exemption

Effective January 1, 2020, any for profit business covered by the CCPA and having California resident employees, will be required to disclose to individuals (job applicants to, employees of, contractors of, owners of, directors of, officers of, medical staff members of that business) at the time or before the personal information is collected, the categories of personal information collected and processed in the context of the employment relationship, and the purposes for which the categories of personal information shall be used.

How can we help?

If you are a covered employer under the CCPA, Reyes & Schroeder Associates, P.C. can help draft the necessary disclosure forms and privacy policies to ensure proper compliance with this new law. Please call our office at 323-553-1541 and speak with our Certified Information Privacy Professional Attorney, Michael W. Schroeder (CIPP-US), for assistance.

bottom of page