Scheduling Employees To Work In California: Easier Said Than Done Mar 3, 2023
Nancy “Niki” Lubrano, Partner & Co-Chair of CDF’s Class Action Defense Litigation Practice Group, recently authored the article “Scheduling Employees To Work In California: Easier Said Than Done – Tips on California wage and hour compliance,” for the Workforce Management Time and Attendance February 2023 edition.
Ten CDF Attorneys Listed as 2023 Southern California Super Lawyers Jan 30, 2023
It’s Not What You Said, It’s How You Said It: LaCour Signals a New Risk For Arbitration Agreements
It’s Not What You Said, It’s How You Said It: LaCour Signals a New Risk For Arbitration Agreements
DIR Releases California Workplace Know Your Rights Template
DIR Releases California Workplace Know Your Rights Template
USCIS Implements Wage Based H-1B Visa Distribution System for FY 2027
USCIS Implements Wage Based H-1B Visa Distribution System for FY 2027
District Court Rules That California’s Law Authorizing PERB to Govern Private Sector Labor Relations Is Preempted
District Court Rules That California’s Law Authorizing PERB to Govern Private Sector Labor Relations Is Preempted
The NLRB’s Quorum is Back – What Can Employers Expect?
The NLRB’s Quorum is Back – What Can Employers Expect?
A Year-End Compliance Checklist for California Employers
A Year-End Compliance Checklist for California Employers
CDF Webinar: Wage & Hour Watch: What California Employers Need to Know Now
Minimum Wage, Overtime, Meal/Rest Breaks, Predictive Scheduling, Prevailing Wage—Plus 2026 on the Horizon
Marie D. DiSante Named 2026 Best Lawyers® “Lawyer of the Year” in the Orange County Area Aug 21, 2025
CDF Webinar (August 20, 2025): AI, Algorithms & Employer Protection — What You Need to Know
Join CDF’s Privacy and AI Practice Group attorneys, Dan Forman, Dalia Khatib and Linda Wang, on August 20, 2025 at 10:00 AM (Pacific) for a timely discussion on how emerging AI regulations and privacy laws are reshaping workplace compliance and litigation risk.
CDF Webinar: NLRB Happenings & Republican Sponsored Pro-Union Legislation
Join CDF Partners Mark S. Spring and Tashayla Billington for a focused webinar on key NLRB developments since January, including the impact to employers from past and future Board Member composition changes, NLRB General Counsel appointments, new NLRB GC Memorandum from the Acting NLRB GC, and NLRB budget constraints.
Reminder: Minimum Wage Hikes Take Effect Tomorrow (July 1)
By: Reminder: Minimum Wage Hikes Take Effect Tomorrow (July 1)
On July 1, 2025 new increased minimum wage rates will be effective in many California cities and counties. Many municipalities are increasing the minimum wage across the board, and others have industry-specific increases. A more full explanation of the causes and specific minimum wage increases can be found in our previous blog post. California employers are strongly encouraged to review the applicable minimum wage in their municipalities to ensure they are paying the correct rates come July 1.
Todd Snyder Agrees to Pay $345,178 Fine to The CPPA and Other Equitable Relief
By: Todd Snyder Agrees to Pay $345,178 Fine to The CPPA and Other Equitable Relief
By: Todd Snyder Agrees to Pay $345,178 Fine to The CPPA and Other Equitable Relief
Last month, the Enforcement Division of the California Privacy Protection Agency (“the Privacy Police”) and Todd Snyder, Inc. (“Snyder”) resolved the investigation into Snyder’s website’s opt-out methods from November 1, 2023 to December 31, 2024 that allegedly violated the California Consumer Privacy Act (“CCPA”).
Snyder, a New York based men’s clothing retailer, operated retail stores and a website. The website utilized third party tracking software to help it with analytics and cross-context behavioral advertising. While Snyder told consumers that they could opt-out, the Privacy Police claimed that the website was not properly configured to actually allow customers to opt out. One issue was that the website’s “consent banner” would appear and then instantaneously disappear preventing consumers from opting out. In addition, when a consumer was able to reach the opt-out option, the Privacy Police claimed that Snyder was culpable of requiring an improper verification standard to persons who wished to opt out. Snyder required all consumers attempting to opt-out to verify the person’s name, email, country of residence and submit a photograph of the consumer holding official identity documents, like a driver’s license.
The Privacy Police criticized Snyder for:
- Allowing a third-party to manage Snyder’s website without adequate supervision by Snyder;
- Forcing consumers who wished to opt-out of sale/sharing to provide verification as such requests do not require verification under the CCPA;
- Requiring more identification information to opt-out than Snyder required when consumers made a purchase; and
- Requiring consumers to provide government identification documents with Sensitive Personal Information (“SPI”) which might decrease opt-out requests due to concerns about identity theft.
Take Aways
Snyder did not admit to liability for any violation of the CCPA and the full scope of the Privacy Police’s investigation and extent of potential penalties is not published in the Stipulation. The expedited resolution in the first four months of 2025 demonstrates that Snyder must have concluded that an expedited settlement, including payment of over $345,000 in fines and providing the Privacy Police with confirmation that it has developed new procedures to handle SPI and procedures to monitor third parties to ensure compliance with CCPA was the most efficient way to dispose of the investigation, legal fees and risks of greater penalties.
The Privacy Police monitor California and out-of-state corporations, alike. Any business that operates a website that shares or sells consumer information for 100,000 or more consumers should review their policies and opt out procedures to ensure compliance with the CCPA. Owners of commercial websites will be held responsible for monitoring consumer Opt-Out requirements, even if they believe that they have delegated such monitoring to third party vendors. Finally, ensure that the opt-out requirements comply with the CCPA and do not require unnecessary verification information or copies of government documents that contain personal identifying information.
Conclusion
The CCPA signifies a major advancement in consumer privacy protection, necessitating businesses to adopt proactive measures to ensure compliance. Contact Dan M. Forman, Linda Wang or your favorite member of CDF’s Privacy Practice Group to better understand potential penalties and the importance of safeguarding consumer data.