Clifford Chance
One "Fine" Day? Insights From The First Fine Issued By The California Attorney General Under The CCPA
September 6, 2022
On August 24, 2022, the California Attorney General (CAG) announced a $1.2 million settlement with Sephora to resolve allegations that the consumer goods retailer violated the California Consumer Privacy Act (CCPA) by failing to disclose to consumers that it was selling their personal information. The settlement is notable not only because it is the first civil penalty issued under the statute, but also because it confirms a broad interpretation of what constitutes a "sale" of personal information under the law and the requirement for websites to respond to global privacy controls. The action also gives insight into the state's focus with regards to enforcement of the CCPA as the state prepares for changes to come in 2023.
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