SIFMA, as part of a coalition with 16 other associations, provides comments to the California State Assembly opposing a privacy policy bill (AB 242), as written.  The bill would require a privacy policy to be: no more than 100 words, written in clear and concise language, written at no greater than an 8th grade reading level, and to include a statement indicating whether the personally identifiable information may be sold or shared with others, and if so, how and with whom the information may be shared.

The Coalition strongly supports simpler, clearer privacy policies and is strongly committed to protecting the online privacy of consumers. However, this legislation would create significant uncertainty and class action risk for businesses that provide key benefits and services to California residents.

AB 242 would, if enacted, be extremely impractical and unworkable. The Coalition believes it is impossible to create an informative privacy policy that covers the elements required under California’s Online Privacy Protection Act with 100 words; and notes that the California State Legislature’s own privacy policy has more than 100 words.