"Even if the [California Consumer Privacy Act of 2018 (CCPA)] is ultimately determined to be preempted in the context of ERISA plans, it will still apply to data collection by an employer in its capacity as an employer, as well as data related to benefits and policies not covered by ERISA. This includes information collected by an employer in connection with administering vacation, sick leave, paid time off or leaves of absence. Other benefits that are generally not subject to ERISA include health savings accounts, dependent care flexible spending accounts, many short-term disability plans and certain voluntary benefits."  MORE >>