Suggested Enhancements to “Commission-Approved Compliance Guidelines” in the American Privacy Rights Act

On April 7, 2024, Senate Commerce Committee Chair Maria Cantwell and House Energy and Commerce Committee Chair Cathy McMorris Rodgers released a discussion draft of the American Privacy Rights Act (APRA), a comprehensive federal consumer privacy framework built on prior congressional efforts including the American Data Privacy and Protection Act (ADPPA). On May 21, 2024, Rep. Rodgers along with House Commerce Subcommittee Chair Gus Bilirakis (R-FL) released a second discussion draft. The analysis in this policy note is based on the May 21 draft.

In this policy note, CIPL offers the following suggestions to enhance the effectiveness of APRA Section 115: “Commission-Approved Compliance Guidelines”:

• Streamline the approval process to align with widely recognized certification schemes, and
• Expand the availability of Compliance Guidelines to all entities.

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