Checklist for Addressing Employee Data Rights Requests

The ramp‑up period for honoring employees’ rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), is over. On July 14, 2023, the California AG announced an investigative sweep focused on employee data, with letters sent to unnamed large employers in the state “requesting information on the companies’ compliance with the CCPA with respect to the personal information of employees and job applicants.” The sweep puts California companies on notice that the AG's office is not waiting to enforce the CCPA/CPRA's requirements around PI collected in the recruitment and employment context. This targeted checklist, based on our previous articles and input from a Littler Mendelson expert, can help companies subject to the CCPA as they respond to employee rights requests. See “In‑House Insight on Handling Data Subject Access Requests Under Multiple Privacy Regimes” (Nov. 3, 2021).

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