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California Consumer Privacy Act: The Challenge Ahead CCPA and Employee Data

Although the new California Consumer Protection Act of 2018 (CCPA) was never intended to apply to employee data, the subject has been under debate since it first was introduced on June 21, 2018. Some are skeptical, arguing that the law is meant to be a general consumer protection measure, but others have pointed out some broadly drafted provisions that legislature may have intended to cover employee data. This includes the laws plain language definition of Consumer under the CCPA, the findings that i[t] is almost impossible to apply for a job without sharing personal information, the CCPAs definition of personal information and the fact that there is nothing in the legislative history suggesting an intent to exclude employee data.

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