New CCPA Compliance Requirements for Employers

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Amendment of the California Consumer Privacy Act (the “CCPA”) by the California Privacy Rights Act (the “CPRA”) in 2020 will see a new set of compliance requirements for employers beginning on January 1, 2023. These requirements concern the collection of personal information by companies subject to the CCPA. The personal information at hand relates to employers’ employees, job applicants, and actual or prospective business customers, vendors, and suppliers.


For the past few years, providing a notice of collection and reasonably safeguard personal information were the only major obligations the CCPA imposed upon employers. This is due to a partial exemption under the CCPA for information collected in the context of employment. However, from January 1, 2023, this partial exemption for employers will expire. The partial exemption was proposed to be extended until January 1, 2026, however, August 31, 2022, was the last day on which the California State Legislature could have passed a bill for an extension.

Main Takeaways

So, what does this mean for employers? Starting from January 1, 2023, employees of CCPA-covered employers will have increased rights, and employers will have greater compliance obligations. The new rights of employees include, but are not limited to:

  • The right to know the type(s) of personal information that their employer collects, shares, sells, or discloses, as well as the right to make a request that the employer disclose personal information collected;
  • The right to rectify or correct the personal information that their employer maintains;
  • The right to delete any or all personal information that the employer has collected; and
  • The right to limit use and disclosure of sensitive personal information.

Employers should take steps to prepare for their new obligations under the CCPA and CPRA, including assessing the location of personal information and creating a data inventory; assessing current records retention policies; and reviewing vendor contracts that process employee personal information.

For more information about the new CCPA obligations for employers and the steps you need to take to ensure compliance, please contact us at

This material is provided for informational purposes only. It is not intended to constitute legal advice, nor does it create a client-lawyer relationship between MNK Law and any recipient. Recipients should consult with counsel before taking any actions based on the information contained within this material.