CFA and Coalition Submit Comments on New Jersey Data Privacy Act Rulemaking
CFA, the Electronic Privacy Information Center (EPIC), New Jersey Citizen Action (NJCA), TechEquity Action, and Virginia Consumer Council submitted comments in response to the New Jersey Division of Consumer Affairs’ call for public input on their implementation of the New Jersey Data Privacy Act. We commend the Division for its work to establish data privacy protections for residents of New Jersey. The state of privacy legislation and regulation in the United States is a patchwork of overlapping but non-identical requirements that are frequently shifting as new developments and technologies come to the fore. As we note many times throughout this comment, the NJDPA as enacted falls short of the rules needed to adequately protect New Jersey residents’ privacy. We urge the New Jersey Legislature to consider amending the NJDPA to place substantive limits on data collection and processing rather than relying on businesses to determine the appropriate purposes for processing and simply disclosing those purposes to the consumer.
