Grant Davis-Denny, Jordan Navarrette, Nefi Acosta on Privacy Act

Munger, Tolles & Olson litigators Grant A. Davis-Denny, Jordan X. Navarrette and Nefi D. Acosta analyzed the impact of the California Consumer Privacy Act (CCPA) and its potential shortcomings in a Law360 article published on July 2, 2018.

As the authors explain, CCPA came together quickly in response to a proposed ballot initiative called the California Consumer Privacy Act of 2018. The bill is set to become law on Jan. 1, 2020 and, according to the authors, it will “dramatically change the privacy landscape in the United States.”

Mr. Davis-Denny, Mr. Navarrette and Mr. Acosta explain that the scope of the law is broad because “the CCPA’s new duties apply to nearly any data that identifies, relates to, describes or can be linked or associated with a California resident or household.”

They also delve into the potential problems the law could create. Because it was hastily written, “(t)he CCPA has significant drafting defects” and “contains ambiguities that lawyers, courts and the regulated community will have to work through.” In the article, the authors raise several questions left unanswered by how the bill is currently drafted.

Mr. Davis-Denny is a litigator who focuses his practice on taking complex matters to trial and counseling clients on rapidly changing areas of law. He counsels companies in the areas of data security, privacy and antitrust. His data security and privacy practice includes proactive compliance advice, incident response and litigation. Mr. Davis-Denny holds a CIPP/US (Certified Information Privacy Professional) certification from the International Association of Privacy Professionals.

Mr. Navarrette is a litigator. His practice includes counseling companies on the potential ramifications of proposed data privacy legislation.

Mr. Acosta is a litigator. He is a Certified Information Privacy Professional in both U.S. and European regulations (CIPP/US & CIPP/E).