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Friday, January 29, 2021 So, My Privacy Notice Does Not Fully Comply with the CCPA. Can I Get Sued? The CCPA permits consumers to “institute a civil action” only where certain types of personal information are “subject to an unauthorized access and exfiltration, theft, or disclosure.” 1 The CCPA does not provide a private right of action, nor does it provide statutory damages, if a business violates its obligation to provide notice concerning its privacy practices. 2 The California Unfair Competition Law (UCL) defines “unfair competition” as including “any unlawful, u...

Overview On December 10th, the Office for Civil Rights (OCR) at the U.S. Department of Health and Human Services (HHS) announced significant proposed changes to the Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule. The announcement continues a recent flurry of proposed rules at the end of the year and the term of the current administration. If finalized, the proposed rule would make numerous changes to the HIPAA Privacy Rule, including requiring a variety of operational changes from covered entities.  While the proposed changes primarily impact covered entities, some ...