In the prior Part 4 of this series, we explained how CCPA cybersecurity audits are likely to surface in CalPrivacy and California Attorney General enforcement actions, and how that regime impacts governance and executive responsibility.
Karimah represents clients in consumer financial services law, business disputes, and complex commercial litigation in federal and state courts.
In Part 1 of this series, we outlined the basics of the California Consumer Privacy Act’s (CCPA) new cybersecurity audit requirement: who is covered, when audits are required, and the key obligations to keep in mind. In Part 2, we explored the mechanics and explained what the California Privacy Protection Agency (CalPrivacy) expects the cybersecurity audit to look like in practice, including what must be evaluated, who may conduct the audit, how thorough it must be, and what goes into the audit report.
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