ESA Comments on CPPA Efforts to Implement Regulation Under CPRA

  • 11.08.2021
  • Statements and Filings

Via Email

California Privacy Protection Agency Attn: Debra Castanon
915 Capitol Mall, Suite 350A Sacramento, CA 95814

RE: Preliminary Comments on Proposed Rulemaking under the California Privacy Rights Act of 2021 (PRO 01-21)

Dear Ms. Castanon:

The Entertainment Software Association (“ESA”)1 submits these comments in connection with the California Privacy Protection Agency’s (“CPPA”) preliminary efforts to implement regulations under the California Privacy Rights Act (“CPRA”).2

ESA respectfully requests that the CPPA adopt regulations that:

  • Discourage fraudsters and other bad actors from attempting to use the correction right to undermine the security or integrity of the service or facilitate their unlawful or malicious conduct.
  • Ensure that any technical specifications for the voluntary opt-out preference signal are consistent with existing children’s privacy laws and reliably convey a parent’s or user’s choice.
  • Provide consumers meaningful access to personal information, while maintaining the safety, security, and integrity of the business’s services.
  • Clarify what constitutes “dark patterns” and “precise geolocation” information to align with the Federal Trade Commission’s precedent and guidance.
  • Consistent with the statutory text, specify that consumers can opt out of automated decisionmaking only where such data processing uses or discloses sensitive personal information, and ensure that disclosing meaningful information about the logic of such data

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