November 15, 2022
Points of Discussion
Colorado Privacy Act: CPA follows the template of Virginia, Utah, and Connecticut as opposed to the CPRA model
Exemptions under CPA: De-identified data, employee data, B2B, federally regulated industries
Consumer Rights: Right to opt out, access, correct, delete, portability, and understand what info businesses collect. Consumers must be given the option for universal opt-out consumers are required to opt-in for the collection and use of sensitive PI.
Business Obligations under CPA: Notice, Purpose, Security, Consent
Limited Right to cure till January 1, 2025, and no private right of action under the law
Timeline and status of the rules
Definition of terms
Universal opt of mechanism
Privacy Policy: what approach to follow
Consent: When and how you need to obtain consent; avoiding dark patterns
Profiling: transparency, opt-out, consent, DPAs
Data protection assessments: specific requirements and timings
Loyalty programs
(Co-Leader of Privacy and Data Security Group at Ballard Spahr LLP)
Founder & CEO
Meru Data LLC