To the California Privacy Protection Agency: Don’t harm workers and consumers

How our data is used can have massive impacts on our daily lives. To keep pace with emergent technologies like automated decision-making tools (ADMTs, also known as automated decision systems), we need common-sense guardrails that encourage innovation, protect workers’ and consumers’ privacy, and build public trust.

The current draft regulations on ADMTs and risk assessments on the desk of the California Privacy Protection Agency fall short of what we need. Our coalition of labor and civil society groups has advocated continuously for strong regulations that protect worker and consumer privacy and dignity, but our calls have been left unanswered.

TechEquity joined more than 40 organizations, including the ACLU California Action, California Federation of Labor Unions, SEIU California, the UC Berkeley Labor Center, and more, in an open letter highlighting the harms that the current proposed regulations would bring to workers and consumers in California:

1. Definitional changes leave large swaths of workers and consumers unprotected by the proposed regulations.
2. The revised notice and data access regime will not work for workers and consumers.
3. The revised ADMT opt-out provisions have become even more inaccessible to workers.
4. The Risk Assessment requirements have become weak tools for identifying and addressing ADMT harms.
5. In sum, the revised regulations fail to meet the spirit and substance of the rulemaking charge that was given to the CPPA by voters, particularly in the area of automated decision-making technology.

You can read the full letter below: