Short answer: Company email and chat are full of employees' personal data, and California's CCPA now covers it: the Attorney General says the exemptions for employment-related and business-to-business personal information expired December 31, 2022. Treat employee and contact data as personal data in scoping and de-identification.
What changed
The California AG: 'The exemptions for employment-related personal information and personal information reflecting business-to-business transactions ... expired on December 31, 2022' (California AG).
Who the CCPA covers
For-profit businesses doing business in California that have gross annual revenue over $25 million, buy, sell or share the personal information of 100,000+ California residents or households, or derive 50%+ of revenue from selling it (California AG).
What to do
- Exclude HR, payroll, medical and investigation records.
- Ask how the buyer transforms names and identifiers; Mode says personal information is transformed before its AI customer sees the data (Mode FAQ).
- Check your employee privacy notice.
This is general information, not legal advice. Talk to your own attorney or compliance advisor before you share or license any records.
What could your company's records be worth?
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Frequently asked questions
Does this apply outside California?
The CCPA covers California residents. Other states have their own laws; ask counsel.
Do we need employee consent?
That depends on your notices and applicable law. Ask counsel.
Sources
- California Attorney General: CCPA overview and FAQoag.ca.gov
- Mode affiliate FAQ (PDF, dated Oct 14, 2026)bizbuydata.com
Referral-fee disclosure: we may be paid by a program if your company signs with it after using this site. General information only, not legal advice.
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