Resolution Economics AI Audit Team Provides Expert Comments on Proposed CCPA Regulations for Automated Decision-Making Technology

The Resolution Economics AI Audit Team submitted expert Comments in response to the California Consumer Privacy Agency’s proposed updates to the California Consumer Privacy Act (“CCPA”) regulations. Based on our Team’s expertise in assessing and evaluating AI- and algorithmic-based employment tools, our Comments focused on the provisions of the proposed regulations that address what the Agency refers to as employment-related “automated decisionmaking technology (ADMT).” Our Comments urge the Agency to provide greater clarity regarding compliance requirements, methodological standards, and the nuanced distinctions among AI model types, particularly as regards the different approaches needed when dealing with generative AI.