Last month, the California Privacy Protection Agency (CPPA) issued an invitation for preliminary comments on potential updates to CCPA regulations addressing notices and disclosures and the handling of employee data. Those with questions or concerns about the CCPA’s application to employment information submitted feedback by the deadline on May 20.

The CPPA is considering whether to amend existing regulations or adopt new rules governing privacy notices (e.g., privacy policies, notices at collection, and rights notices) and their application to workforce data. The CPPA therefore sought stakeholder input on both consumer-facing disclosures and employment lifecycle data practices, including hiring, active employment, and offboarding. Notably, the agency offered the comment opportunity not only to businesses, but also to employees, applicants, and other consumers.

Key Areas for Consideration

Employee Notice Timing and Delivery: The CPPA asked when and how employees receive notices (e.g., at hiring, during employment, or at offboarding), highlighting uncertainty around optimal timing and format for workforce-specific disclosures.

Application of CCPA Rights in the Employment Context: The CPPA also sought input on a pain point for employers, namely managing the exercise of consumer rights under the CCPA. This included questions about applicant and employees’ experiences exercising access, deletion, or correction rights suggesting a need for clearer rules on scope, verification,...

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