Consumer Reports provided feedback in response to the California Privacy Protection Agency’s (CalPrivacy) Invitation for Preliminary Comments on Notices & Disclosures and Employee Data.
CR noted that privacy notices and disclosures often have little utility for consumers themselves; instead, privacy laws should set default rules that restrict the collection and use of consumer information. However we also noted that privacy notices can play an important role for expert audiences and those with a particular interest in holding companies accountable for promises made to consumers—such as regulators, journalists, and advocates.
With that in mind, we offered the following suggestions for how to improve CCPA’s existing privacy notice requirements:
- Requiring businesses to plainly state whether they believe themselves to be covered by CCPA;
- Requiring businesses to share the precise list of third parties with whom they have sold or shared consumers’ personal information;
- Requiring businesses to detail their process for verifying consumer requests;
- Strengthening enforcement against businesses with broken privacy request links.
To read the full comments, please see the attached PDF.