The CA State Privacy Agency enabled by Proposition 24 in 2020 (yep, we opposed it at that time, but here we are), is taking its first stab at refining the rules that govern the state data privacy laws CCPA and CPRA.

And the news is good. The proposed rules by the agency are, in large part, strong and consumer-protective. But nothing is perfect.

Here are the comments that a group of privacy advocates, including us, co-wrote and submitted to the agency.