A close-up of hands typing on a black computer keyboard. This overlapping authority and jurisdiction can lead to so-called “piling on,” where one investigation by or settlement with a regulatory authority is followed by another. (Credit: Chris Ratcliffe/Bloomberg)

Data protection regulation in the United States is famously fragmented. A patchwork of federal and state requirements overlap, and periodically conflict, when it comes to the protection of consumer data. And these overlapping regulatory regimes do not even agree when it comes to the definition of “consumer.”

The California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), defines a “consumer” as “a California resident,” whether that person is acting in a personal or business capacity, even in the employment arena. Realizing the broad reach of this definition, the California Legislature included a carve-out in an early amendment to CCPA that excluded employment-related and certain business-to-business information from the scope the Act.

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