CCPA Close-Up: Data Mapping, Enforcement and Understanding the GLBA Carveout

The amendments to the CCPA that the California legislature passed at the end of its 2019 session leave many companies, including those subject to the Gramm-Leach Bliley Act, even more uncertain about whether the Act applies to them and, if so, how to comply. In a recent interview with the Cybersecurity Law Report, Ropes & Gray partner Melissa Bender and counsel Catherine Skulan discussed how financial institutions subject to the GLBA, such as private fund managers that are registered as investment advisers with the SEC, can determine if they are also subject to the CCPA. The first article in our series covering this discussion provided their thoughts on how companies can complete a data-mapping exercise to help with CCPA compliance and outlined recent amendments and anticipated enforcement steps. The second article details how the GLBA carve-out will provide some, but likely not complete, relief from compliance with the Act.

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