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California: Governor approves bill on vehicle identification and registration through alternative devices

The California Governor approved, on 29 September 2022, Assembly Bill ('AB') 984 on 'Vehicle identification and registration: alternative devices'. In particular, AB 984 requires that employers shall not use an alternative device to monitor employees except during work hours, and only if strictly necessary for the performance of the employee's duties. Moreover, AB 984 establishes that employers that choose to install such a device must provide notice to employees prior to monitoring with the device, including:

  • a description of the specific activities that will be monitored;
  • a description of the worker data that will be collected as a part of the monitoring;
  • a notification of whether the data gathered through monitoring will be used to make or inform any employment-related decisions, including, but not limited to, disciplinary and termination decisions, and, if so, how, including any associated benchmarks; and
  • a description of the vendors or other third parties, if any, to which information collected through monitoring will be disclosed or transferred.

AB 984 is due to take effect on 1 January 2023.

You can read AB 984 and view its history here.

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