California is the only state to treat employees as full “consumers,” providing them the right to an employee notice and employee rights. While California enforcement has not yet focused squarely on employer practices, a fresh call for public comments from CalPrivacy on how to strengthen employee privacy notices and rights signals this may soon change. That means the time is ripe for employers to take note.
Our colleague Odia Kagan, Co-Chair of the firm’s Privacy & Data Security practice, recently detailed the history of California’s employee privacy enforcement efforts and what CalPrivacy’s call for comments may portend for the future, on the firm’s Privacy Compliance & Data Security blog.