What the CPPAs appointments say about enforcement priorities strategy

Lindsey Tonsager spoke with IAPP about staffing the California Privacy Protection Agency’s inaugural board. Ms. Tonsager points out that the board will need to appoint several employees, including an executive director and chief privacy auditor, sooner rather than later. She says staff loans from the attorney general's office are a common practice with past agency appointments, but doing so for the CPPA is not a given due to the exit of Attorney General Xavier Becerra — who was confirmed as secretary of the U.S. Department of Health and Human Services last week — and subsequent shakeup his former office will see.

She adds, “The CPPA's regulations will cover broader ground than the existing CCPA regulations from the attorney general. For example, the new regulations will address opt-outs for cross-context behavioral advertising, opt-outs and access rights for automated decision-making technologies, restrictions on the use of so-called 'dark patterns,' and processes for exercising and responding to new consumer rights.”