When assisting businesses with the commercial aspects of the California Consumer Privacy Act, we advise them that this same law, with “consumer” in its name, also applies to data related to job applicants, employees, contractors, and other California state residents. Some are surprised, but we get to work addressing some nuanced issues, as some CCPA provisions do not neatly fit the employment relationship.
Fortunately, 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. So, if you have questions or concerns about the CCPA’s application to employment information, you can submit that feedback by 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. In short, the CPPA is seeking stakeholder input on both consumer-facing disclosures and employment lifecycle data practices, including hiring, active employment, and offboarding. Notably, the agency is offering this opportunity not only to businesses, but also to employees, applicants, and other consumers.
Key Areas for Consideration
Employee Notice Timing and Delivery: The CPPA asks when and how employees receive notices (e.g., at hiring, during employment, or at offboarding), highlighting...
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