EPIC, Coalition Submit Comments to California Privacy Agency

March 31, 2023

EPIC, the Center for Digital Democracy, and the Consumer Federation of America submitted comments to the California Privacy Protection Agency to recommend strong regulations implementing key provisions of the California Consumer Privacy Act. The comments include proposals on cybersecurity audits, risk assessments, and automated decision-making systems and urge the agency to protect Californians by drawing on strong existing frameworks and ensuring that consumers’ rights to opt out and receive information are easy to exercise.

“As the agency formulates regulations concerning cybersecurity audits, risk assessments, and automated decision-making, we renew our call to ‘protect consumers’ rights’ and ‘strengthen[] consumer privacy’ at every opportunity, consistent with the expressed will of California voters,” the organizations wrote.

EPIC provided extensive input on CCPA regulations in November 2021, May 2022, August 2022, and November 2022, arguing for consumer-friendly interpretations of the CCPA to guard against exploitative commercial data practices. EPIC also published a detailed analysis of the California Privacy Rights Act—a ballot measure that made substantial improvements to the CCPA—before voters approved it in 2020.

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