Even though the California Public Records Act (CPRA) deferred a majority of the California Consumer Privacy Act’s (CCPA) employee-related substantive requirements until January 2023, employers are still required to provide employees with a notice of collection “at or before the point at which” the collection of information occurs. The following information must be collected: a list of the categories of personal information that will be collected, the business or commercial purpose for which the information is being collected, information on how to opt-out of the sale of personal information, and information on how to find the company’s complete privacy notice. After Jan. 1, 2023, CPRA also requires the collection of whether that information is “sold or shared” and the “length of time” that the business intends to retain each category of personal information.
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