Updating Compliance Programs to Address the CPPA’s Regulations on ADMT and Risk Assessments

Over the past two years, the California Privacy Protection Agency (CPPA) has wrestled with drafting regulations on automated decision-making technology: how to define it; the requirements for businesses that use it; and how consumers can exercise their knowledge, access and opt-out data rights. The CPPA has now voted to finalize those rules along with regulations on how businesses should conduct risk assessments. In this guest article, McDermott Will & Schulte attorneys John Ying and Amy Pimentel break down the draft regulations’ key requirements, provide businesses with a roadmap to analyze whether they are in scope, and offer advice on building or updating compliance programs to address new obligations. See “California’s Pending Automated Decision-Making Technology Regulations Will Further Focus Consumers’ Attention on AI” (Feb. 5, 2025).

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