While we can hope for a comprehensive federal data privacy and security law businesses must be prepared for the multiple consumer requests for data access or deletion and implement reasonable data security programs to avoid the likely lawsuits to come under the CCPA private right of action. Congress has had difficulty getting any legislation passed, which does not bode well for any comprehensive federal data privacy or breach notification laws. In the absence of a comprehensive federal data breach notification or other federal data privacy and security law, businesses will have to continue to consider the patchwork of state and federal laws discussed in this Guide.
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