CalChamber Submits Comments to Privacy Agency

The California Chamber of Commerce Privacy and Cybersecurity Committee has submitted comments to the California Privacy Protection Agency to assist it in developing regulations in accordance with its authority.

In September, the agency invited comments on all aspects of its rulemaking authority under the California Privacy Rights Act of 2020 (CPRA), but specifically requested comments concerning the creation of rules for: (i) cybersecurity audits and risk assessments performed by businesses; (ii) automated decision making; (iii) audits; (iv) the consumers’ right to delete, correct, and know personal information; (v) the consumers’ right to opt their personal information out of selling or sharing; (vi) the consumers’ right to limit sensitive information use and disclosure; and (vii) information required to be provided in a consumer request to know.

In its comments, the CalChamber committee provided guidance on issues including regulations related to automated decision making, agency audits, and processing of information that presents a significant risk to consumer privacy or security. The CalChamber also provided substantive comments regarding the right to delete, correct, and know, and the right to opt-out, specifically with regard to sensitive personal information.

The agency’s statutory deadline to promulgate regulations is July 1, 2022. With the agency’s Invitation for Preliminary Rulemaking now closed, the agency is next expected to publish draft regulations and solicit formal public comment as prescribed in the California Administrative Procedures Act. And while the agency is under no obligation to issue draft regulations with haste, its July 1, 2022 deadline for promulgating regulations means there is a limited amount of time for the agency to engage in the public comment process before doing so.

Privacy Protection Agency

The California Privacy Protection Agency (CPPA) was created when California voters passed the California Privacy Rights Act (CPRA) in November 2020. To implement the law, the agency was established and granted authorization to update and adopt regulations.

Staff Contact: Shoeb Mohammed

Shoeb Mohammed
Shoeb Mohammed joined the CalChamber in December 2019 as a policy advocate. He specializes in privacy and cybersecurity, economic development, technology, telecommunications and elections/fair political practices issues. Mohammed is an experienced litigator who advised clients on matters such as trademark; employment; business planning; proprietary software; and technology-related business cases. He came to the CalChamber from Knox Lemmon & Anapolsky, LLP, where he provided product and general counsel for various industries. Mohammed earned a B.A. in political science at California State Polytechnic University, Pomona; a J.D. from the McGeorge School of Law, University of the Pacific; and a Certificate in Disruptive Strategy from Harvard Business School Online. See full bio.