Agency Requests Comment on State Consumer Privacy Regulation

The California Privacy Protection Agency ("CalPrivacy"), a state agency established to implement and enforce California privacy laws, requested preliminary comment on (i) the implementation of rules governing consumer privacy notices; and (ii) the collection, use, disclosure, or retention of job applicant or employee personal information.

On notices and disclosures, CalPrivacy posed questions about what information consumers find most useful or confusing in privacy policies, what challenges businesses face in drafting clear disclosures, and how effective notice can be delivered across non-traditional devices such as smartwatches, smart TVs, and gaming systems. On employee data, CalPrivacy asked whether workers actually receive and understand their privacy notices at various stages of employment - hiring, active employment, and offboarding - and whether they are able to exercise their legal rights in practice. The agency also asked what steps businesses were taking to ensure that service providers and contractors comply with California consumer privacy requirements.

CalPrivacy stated that the request for preliminary comments "do not reflect any decisions made by CalPrivacy regarding future rulemaking."  Comments are due by May 20, 2026.