California’s governor may soon sign into law a one-year delay of the California Consumer Privacy Act’s (CCPA) full application to human resources data. Under the current CCPA, employers must provide HR individuals with a “Notice at Collection” when or before collecting their individually identifiable information, and HR Individuals are granted the right to recover up to $750 in statutory damages from a company that breaches its human resources personal information due to a failure to implement reasonable safeguards. The full CCPA would impose heavy burdens on employers with respect to human resources data, as well as for the notice at collection and private right of action, including two key sets of obligations on covered businesses, but the delay could provide a year’s respite from complying with these and other obligations of the CCPA.
