SIIA and State Privacy and Security Coalition’s Letter of Opposition on AB 331

The State Privacy and Security Coalition Inc strongly but respectfully OPPOSE AB 331 (Bauer-Kahan) as amended March 30, 2023, relating to the development and deployment of automated decision tools (ADTs). We agree that it is not only laudable, but critical to reduce bias and discrimination in consequential decisions impacting people. At the same time, we believe these issues exist whether the decision is human-made from start to finish, or a biproduct of using or incorporating new technologies in the decision-making process. We believe it is critical that any regulatory efforts proceed with precision, particularly as technology is still developing and has the potential to reduce, if not one day eliminate, such undesirable outcomes. There are many other beneficial uses of this technology that should not be overlooked. Just to name a few: they can automate repetitive tasks (such as entering data in two places at once), minimize errors by comparing current work to past work, enable quick approvals and access to credit that would otherwise take weeks, and protect consumers against fraudsters by assisting in the identification of uncharacteristic account activity.

Ultimately, overregulation in this space can easily undermine many beneficial uses of ADT—including the ability develop and deploy these tools in a manner that can in fact reduce the instances and effects of human bias. To that end, we urge greater clarity, precision, and narrowing of the bill to avoid unintended consequences but, for all the aforementioned reasons, must OPPOSE AB 331 (Bauer-Kahan) in its current form.

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