March 25, 2021
March 2021—In accordance with increased privacy protections that were passed into law by the California Privacy Rights Act (“CPRA”) in the November 2020 election, state officials announced the names of appointees to the new California Privacy Protection Agency (CPPA) on 17 March. The CPRA mandated the creation of the CPPA. This agency, charged with protecting Californian’s privacy rights, is the first of its kind in the United States. The CPPA will assume powers previously held exclusively by the California Attorney General and is expected to begin rule-making as early as July of this year. The five new board members have backgrounds in privacy, technology, and consumer rights.
New Chair of the CPPA
Jennifer M. Urban, the newly appointed chair of the CPPA, is a law professor from UC Berkeley. She has directed technology law clinics at Berkeley, USC, and Stanford. Other board members include: (1) John Thompson, a senior vice president of government relations at LA2028 who previously held positions at Southern California Edison and in the US Senate and House of Representatives; (2) Angela Sierra, a recent Chief Assistant Attorney General of the California Public Rights Division, including overseeing the Consumer Protection Section’s Privacy Unit; (3) Lydia de la Torre, an of-counsel privacy attorney for Squire Patton Boggs and a privacy law professor at Santa Clara University Law School, where she co-directed the Privacy Certificate Program; (4) and Vincent Le, a technology equity attorney at the Greenlining Institute who focuses on consumer privacy, closing the digital divide, and biases in algorithms.
Emphasizing the importance of the CPPA, California AG Becerra stated, “The California Privacy Protection Agency marks a historic new chapter in data privacy by establishing the first agency in the country dedicated to protecting forty million Californians’ fundamental privacy rights. [ ]The CPPA Board will help California residents understand and control their data privacy while holding online businesses accountable.”
The New CCPA Agency
For companies that are already complying with the California Consumer Privacy Act (also referred to as the CCPA, making the list of acronyms extra confusing), California’s landmark privacy legislation that went into effect in January 2020, the creation of the CPPA indicates a move towards increased regulatory enforcement of existing privacy law as well as an expectation of increased rulemaking around consumer privacy issues as the new agency starts work. While there was little in the way of enforcement under the Attorney General in 2020, the new agency has been given a substantial budget dedicated entirely to privacy, strongly suggesting that enforcement will be ratcheted up under the auspices of the CPPA.
The new agency has the authority to both implement and enforce the California Consumer Privacy Act (already in effect) and the new California Privacy Rights Act (which goes into effect in 2023). The new board will oversee the appointment of an executive director, officers, and employees for the fledgling agency. Any enforcement actions the new agency brings will go before an administrative law judge, but the California Attorney General will also retain the ability to enforce both the CCPA and the CPRA. Some of the new agency’s first actions will undoubtedly include the creation of additional rules around the implementation of the CPRA, including setting up audit and risk assessment rules.
To learn more about SixFifty and how we can help you on your way towards compliance with the CCPA, click here.
DISCLAIMER: This publication has been prepared by SixFifty, LLC to provide information of interest to our readers regarding legal requirements. It is not intended to provide legal advice or to create an attorney-client relationship. SixFifty, LLC does not provide legal advice.
Written by Marie Kulbeth
Marie Kulbeth is a Co-Founder and General Counsel of SixFifty, and the co-director of BYU LawX, a legal design lab dedicated to solving access to justice problems. She works to make the law straightforward for everyone, regardless of education level or income. Marie keeps her passion for equitable, accessible legal services at the forefront of her career. Her role as...
Full Bio and other articles by Marie Kulbeth
About The Author: Marie Kulbeth
Marie Kulbeth is a Co-Founder and General Counsel of SixFifty, and the co-director of BYU LawX, a legal design lab dedicated to solving access to justice problems. She works to make the law straightforward for everyone, regardless of education level or income.
Marie keeps her passion for equitable, accessible legal services at the forefront of her career. Her role as General Counsel allows her to field-test SixFifty’s products to ensure they’ll work for customers.
Education and Experience
Marie attended Brigham Young University, and spent most of her undergrad studying International Politics and Development. It was during a field study in South Africa that she first decided to become a lawyer. As she researched the new South African constitution and worked with community organizers, Marie became fascinated with the development of the rule of law and how it in turn fosters economic development.
After undergrad, she attended BYU Law, where she continued focusing on improving equity, specifically through access to justice. She spent time interning with a nonprofit at the Human Rights Council in Geneva and with the United Nations International Tribunal for the Rwandan Genocide. At home, she interned with Catholic Charities, focusing on supporting asylum cases. Marie’s work with communities and governments across the globe broadened her understanding of how the law can either uplift or further harm underserved populations.
After law school, Marie worked as a judicial law clerk for the US Fifth Circuit Court of Appeals. She then practiced commercial litigation in Salt Lake City before returning to BYU Law, where she became an Assistant Dean. During her time at BYU Law, Marie built a diversity recruiting program and a storytelling program. Although she has left academia, she continues to keep a hand in by teaching a legal design class at BYU Law School and an undergraduate international politics class that focuses on development and diplomacy at BYU’s Kennedy Center. Both courses help students increase their community engagement and use their skills to create change.
Achievements with SixFifty
Marie’s work with both SixFifty and LawX focuses on making the law less complicated and
more equitable for both companies and individuals.
Marie’s legal specialty is privacy. She has additional focus areas in legal technology; diversity, equity and inclusion; employment; and compliance. She enjoys the opportunity to build products with the legal product team, including pro bono products. This allows her to work with communities she cares about – and complements the work she continues to do at BYU.
With Marie’s guidance and experience, SixFifty is able to offer privacy products that allow even small companies to easily comply with global privacy restrictions. Her passion for making the law accessible to everyone is evident in our pro bono products, which help individuals access free legal help for common issues.
Get to Know Marie
When she’s not helping to advance SixFifty’s mission, Marie travels whenever she can. Keep your eyes open and you may find her anywhere in the world – one of her favorite trips was a seven-day motorbike tour of northern Thailand. She especially loves to canyoneer in southern Utah and explore wilderness areas.
Marie also continues her community development and education work. She is on the board of several nonprofits, including one that runs primary schools in South Sudan and the Utah Tribal Relief Foundation. She recently joined the board of the Mountainland Association of Governments, which focuses on making loans to entrepreneurs from underserved communities who lack access to traditional funding. She’s also a Model UN legend! She is the Executive Director of BYUMUN, Utah’s premier high school Model United Nations learning conference.
Marie loves podcasts and will nerd out on anything related to the law, the history of the English language, and anything done by the people at Radiolab.
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