Comments on the California Consumer Privacy Act (CCPA)

In collaboration with CIS Visiting Research Scholar Jana Gooth, we have (belatedly) submitted comments to the California Attorney General's office regarding California's Consumer Privacy Act (CCPA). This was a cooperative exercise between an information scientist (me) and a German lawyer (Jana), and we were able to work in many valuable insights from Jana's experience working on the General Data Protection Regulation (GDPR) for the European Parliment. As a non-lawyer, many of my concerns focus on the mechanisms by which the law provides notice to consumers, and I emphasized the fact that this legislation perpetuates a notice and consent framework that I and others consider fundamentally flawed. As we look forward towards a future of probable privacy legislation, we are overdue for a serious reckoning on how to rethink our notice and consent mechanisms and to move away from long form legal notices.

A PDF of our comments is posted below. 

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