The California Consumer Privacy Act potentially could impose substantial compliance burdens on and create significant class-action exposure for anyone who employs California residents and has more than $25 million in annual gross revenues. However, these risks aren't a sure thing, because the act (as written) might not apply to employers at all, and a pending bill to amend the act could establish that the CCPA does not apply to employers’ own human resources data. This uncertainty creates a perilous waiting game that must balance the cost of implementing a CCPA compliance program for HR data against the risk that the time, effort and resources invested in that program could be wasted. Littler Mendelson's Philip Gordon offers operational advice for potentially impacted employers for The Privacy Advisor. 
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