BILL ANALYSIS                                                                                                                                                                                                    �



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          Date of Hearing:  April 16, 2013

                           ASSEMBLY COMMITTEE ON JUDICIARY
                                Bob Wieckowski, Chair
                     AB 25 (Campos) - As Amended:  March 14, 2013

           SUBJECT  :  PUBLIC EMPLOYERS: EMPLOYEE SOCIAL MEDIA SITES

           KEY ISSUES  : 

          1)SHOULD LAST YEAR'S LANDMARK LAW BARRING employers from  
            requiring or requesting employees or prospective employees to  
            disclose their PRIVATE username and passwords TO ACCESS THEIR  
            PERSONAL SOCIAL MEDIA ACCOUNTS BE CLARIFIED THAT IT APPLIES TO  
            PUBLIC AS WELL AS PRIVATE EMPLOYERS, AS WAS THE APPARENT  
            ASSUMPTION WHEN IT WAS ENACTED LAST YEAR?

          2)Should there be a broad NEW law enforcement exemption ADDED TO  
            this important employee privacy protection LAW when no such  
            exemption APPARENTLY exists WITH similar laws in other states,  
            WHERE such an exemption COULD VERY WELL be FOUND TO BE  
            UNconstitutional, AND WHERE IT WOULD RISK A "SLIPPERY SLOPE"  
            OF MANY OTHER PUBLIC EMPLOYEES LOSING THE LAW'S PRIVACY  
            PROTECTIONS IN THE FUTURE? 

           FISCAL EFFECT  :  As currently in print this bill is keyed fiscal.
                                          
                                      SYNOPSIS
          
          Last year this Committee unanimously passed the author's AB  
          1844, which ultimately was approved by the Legislature with  
          bipartisan broad support and signed by the Governor.  That bill  
          prohibits an employer from requiring or requesting an employee  
          or job applicant to disclose a username or password for the  
          purpose of accessing his or her personal social media, to access  
          his or her personal social media in the presence of the  
          employer, or to divulge any personal social media content.  When  
          that bill proceeded through the Legislature, it was assumed in  
          the legislative analyses that the measure was intended to apply  
          to both public and private employers.  However after the bill  
          was chaptered, the author learned there is some ambiguity in the  
          current case law as to whether the Legislature needs to  
          explicitly state that such measures, when placed in the Labor  
          Code, are intended to apply to public as well as private  
          employers.  Thus although Labor Code section 980 could be found  








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          to apply to public employers, this bill therefore merely seeks  
          to do what was assumed it did last year -- clarify that public  
          employees as well as their private counterparts are covered by  
          this important consumer privacy protection.  The measure is  
          supported by privacy protection groups and some labor  
          organizations.  

          However various law enforcement organizations oppose this  
          clarification of legislative intent unless an exemption is added  
          permitting them to require or request law enforcement employees  
          or applicants to disclose their private username or password to  
          access their personal social media, to access personal social  
          media in their presence, or to divulge personal social media  
          content.  They contend forced access to these "keys" to open  
          individuals' personal social media accounts is needed for them  
          to be able to most effectively weed out potentially dangerous or  
          unmeritorious job applicants or current employees to maximize  
          public safety.  
           
          However it appears that not only would a special "carve out" for  
          law enforcement be unprecedented in such laws across the  
          country, it would single out a broad group of public employees  
          who are already subject to rigorous background reviews to  
          protect public safety.  In addition, such a broad special  
          exemption very well could be found to be unconstitutional under  
          the Fourth Amendment to the U.S. Constitution.  This is because  
          the exemption would appear to allow law enforcement to intrude  
          upon a reasonable expectation of privacy that law enforcement  
          employees or prospective employees hold in their personal  
          usernames and passwords.  By its very nature, a search of a  
          user's entire social media profile, through forced access to  
          their username and password, would appear to be an unreasonable  
          governmental intrusion because of the inherent inability to  
          properly limit the breadth, or scope, of such a search to only  
          that specific information relevant to his or her fitness for  
          employment.  Given the significant amount of private information  
          contained on social media accounts, including for example race,  
          sexual orientation and age (all protected characteristics under  
          the Fair Employment and Housing Act), this bill, the author  
          argues, without such an exemption, is essential to helping  
          protect the rights of public employees across California.  

           SUMMARY  :  Seeks to clarify the Legislature's intent last year  
          that the prohibition barring employers from requiring or  
          requesting an employee or prospective employee to disclose their  








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          private username or password for the purpose of accessing their  
          personal social media accounts applies to both public and  
          private employers.  Specifically,  this bill  :

          1)Prohibits public employers from requiring or requesting an  
            employee or applicant for employment to disclose a username or  
            password for the purpose of accessing personal social media,  
            to access personal social media in the presence of the  
            employer, or to divulge any personal social media content.

          2)Defines, for the purposes of this chapter, "public employer"  
            as the state, a city, a county, or a district.  

           EXISTING LAW  : 

          1)Prohibits an [private] employer from requiring or requesting  
            an employee or applicant for employment to disclose a username  
            or password for the purpose of accessing personal social  
            media, to access personal social media in the presence of the  
            employer, or to divulge any personal social media content.   
            (Labor Code Section 980.)  

          2)Prohibits employers from limiting employee's political  
            participation or influencing employees' political beliefs.   
            (Labor Code Section 1101.)

          3)Prohibits employers from requiring applicants to submit to  
            polygraph, lie detector, or other similar tests as a condition  
            of employment or continued employment.  (Labor Code Section  
            432.2.)

          4)Permits employers, under certain specified circumstances, to  
            investigate the credit history of prospective employees.   
            (Civil Code Section 1785 et seq.; Labor Code Section 1024.5.)

          5)Permits employers to hire investigators to examine the  
            criminal history and past civil liabilities of prospective  
            employees.  (Civil Code Section 1786 et seq.)

          6)Under the California Fair Employment and Housing Act, limits  
            the information potential employers and potential housing  
            providers can request of applicants.  (Gov. Code Section  
            12920.)

          7)Provides, in the Fourth Amendment to the U.S. Constitution,  








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            that "the right of the people to be secure in their persons,  
            houses, papers and effects, against unreasonable searches and  
            seizures, shall not be violated, and no Warrants shall issue,  
            but upon probable cause, supported by Oath or Affirmation, and  
            particularly describing the place to be searched, and the  
            persons or things to be seized."  (U.S. Const. 4th Amend.)  

           COMMENTS  :  Last year this Committee unanimously passed the  
          author's AB 1844, which ultimately was approved by the  
          Legislature with bipartisan broad support and signed by the  
          Governor.  That bill prohibits an employer from requiring or  
          requesting an employee or job applicant to disclose a username  
          or password for the purpose of accessing his or her personal  
          social media, to access his or her personal social media in the  
          presence of the employer, or to divulge any personal social  
          media content.  When that bill proceeded through the  
          Legislature, it was assumed in the legislative analyses that the  
          measure was intended to apply to both public and private  
          employers.  However after the bill was chaptered, the author was  
          advised that current case law requires the Legislature to  
          explicitly state that such measures, when placed in the Labor  
          Code, are intended to apply to public as well as private  
          employers.  Although this interpretation may be disputed, and  
          there are many Labor Code provisions that do not explicitly  
          state their application to public employees but are nevertheless  
          understood to apply equally to public and private employers,  
          this bill merely seeks to do what was assumed the Legislature  
          did last year -- clarify that public employees as well as their  
          private counterparts are covered by this important consumer  
          privacy protection. 

          According to the author:

               AB 25 seeks to protect the privacy rights of public  
               employees and those seeking jobs in the public sector.  
                Employers are increasingly asking, and sometimes  
               requiring employees or applicants to provide access to  
               their social media and online profiles.  This is a  
               tremendous invasion of privacy.  Asking for this  
               information is akin to requiring someone show you  
               their personal photo album or allowing you to  
               eavesdrop on their private conversations.  Simply  
               because personal information is more readily available  
               than in the past doesn't open the door to employers'  
               demands to have access to it.  Perhaps most  








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               importantly, the tweets, posts, or profile of an  
               individual are no indication of whether or not they  
               are qualified for a position. 

           Labor Code section 980  :  Last year, in response to the world's  
          exploding "technology revolution", Labor Code section 980 was  
          enacted to protect employees' and prospective employees' right  
          to privacy in the workplace.  As evidenced in numerous news  
          reports, a growing number of employers, reportedly, were asking  
          their employees and prospective interviewees for access to their  
          individual social media profiles.  The Los Angeles Times, for  
          example, noted that personal social media profiles frequently  
          provide information about the social media user's sexual  
          orientation, religion, ethnic background, age and marital  
          status-information employers are prohibited from requiring  
          employees to disclose under Government Code section 12920.  ("A  
          Social Media Trend We Don't Like" Los Angeles Times, March 28,  
          2012.)  

          Also following suit, Maryland, Illinois and Michigan, passed  
          laws last year prohibiting employers from requiring or  
          requesting access to an employees' personal social media  
          accounts.  In addition, twenty-eight states, including, but not  
          limited to, Iowa, Hawaii, Massachusetts, New York, Oregon and  
          Washington, have introduced legislation to prevent employers  
          from requiring disclosure of, or requesting access to, personal  
          social media accounts.  

          Specifically, Labor Code section 980 prohibits private employers  
          from requiring employees or prospective employees to disclose  
          their private username or password for the purpose of accessing  
          the individuals' personal social media accounts.  

           There Appears to Be Legal Ambiguity as to Whether Public  
          Employers Are Currently Subject to the Prohibitions of Labor  
          Code Section 980  :  As noted above, when that bill proceeded  
          through the Legislature, it was assumed in the legislative  
          analyses that the measure was intended to apply to both public  
          and private employers.  However after the bill was chaptered,  
          the author learned there is some ambiguity in the current case  
          law as to whether the Legislature needs to explicitly state that  
          such measures, when placed in the Labor Code, are intended to  
          apply to public as well as private employers.  Thus although  
          Labor Code section 980 could be found to apply to public  
          employers, this bill therefore merely seeks to do what was  








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          assumed it did last year -- clarify that public employees as  
          well as their private counterparts are covered by this important  
          consumer privacy protection.    

           Similar Efforts to Extend Protections to Public Employees in  
          Other States  :  Last year, Illinois enacted H.B. 3782, which  
          amended the Right to Privacy in the Workplace Act to prohibit  
          certain inquiries by an employer.  This year they are amending  
          the Right to Privacy in the Workplace Act to redefine employer,  
          to include any unit of the State or local government.   
          (Importantly, as to be discussed more fully below, that measure  
          does not contain any exemption for law enforcement agencies.)  

           Similar 'Law Enforcement Exemption' Efforts in Other States :   
          Several states have introduced legislation that would prohibit  
          private and public employers from requiring or requesting  
          prospective employees and employees to disclose their private  
          username or password for the purpose of accessing personal  
          social media accounts, which include 'law enforcement'  
          exemptions concerning (1) conducting background checks for  
          employment and/or (2) in the course of law enforcement officer  
          conduct investigations.

          The State of Hawaii introduced H.B. No. 713, which prohibits  
          employers from requiring, requesting, suggesting, or causing  
          employees and potential employees to disclose social media  
          usernames or passwords.  H.B. No. 713 would apply to both public  
          and private employers.  Several law enforcement agencies opposed  
          H.B. No. 713, including the Maui Police Department. In their  
          letter of opposition to H.B. No. 713, the Maui Police Department  
          stated, "in the interest of public safety and the integrity of  
          the law enforcement agencies that [H.B. No. 713] would affect ?  
          a police applicant's background check should be extensive and  
          thorough?"  
           
          In response to law enforcement opposition, H.B. No. 713 was  
          amended to include a similar "law enforcement" exemption,  
          addressing employee applicant background checks, which allowed  
          law enforcement to request or require an employee or potential  
          employee to access a personal account in the presence of a law  
          enforcement agency employer, or to disclose any personal account  
          information.  However, on March 1, 2013, the "law enforcement"  
          exemption was removed from H.B. No. 713.  

          The Committee was unable to confirm why the 'law enforcement'  








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          exemption was removed from H.B. No. 713.  However, it is  
          significant that the 'law enforcement' exemption was first  
          amended to include the exemption, in response to opposition from  
          law enforcement, and later removed from the bill.  This may  
          suggest that the Hawaii Legislature ultimately concluded that  
          this exemption would not be a good idea. 
           
          Background Investigation Screening Tools of Prospective Law  
          Enforcement Personnel are Extensive.   As it stands, law  
          enforcement requires prospective employees to submit to an  
          aggressive background investigation process to protect public  
          safety in order to gain employment as a public safety officer,  
          which may include completion of a detailed history statement,  
          submission to a polygraph, and other requirements.  For example,  
          the hiring process for entry-level police officer candidates for  
          the City of Roseville, in Placer County, includes a background  
          investigation.  The background investigation process includes a  
          completion of a detailed personal history statement in the  
          applicant's own handwriting, they are required to submit  
          original certified copies of birth certificates, high school and  
          college transcripts, and an interview by a background  
          investigator.  In addition, the applicant is required to submit  
          fingerprints and submit to a CVSA, a computerized voice stress  
          analysis test, similar to a polygraph.

          Law enforcement applicants with the Los Angeles Police  
          Department are required to complete a personal history form as  
          part of the background investigation portion of the selection  
          process, which includes providing detailed information regarding  
          prior employment, past residences, education, military service,  
          personal information related to finances including current  
          assets and liabilities, tattoo information, marital status,  
          children, a list of family members that will be contacted and  
          asked to comment upon the applicant's suitability for a position  
          in law enforcement and a list of seven references, not including  
          family members, that have known the applicant for at least two  
          years. 

          Thus, it would appear that already existing rigorous background  
          investigation screening tools would reveal any existing  
          discriminatory animus or other dangerous propensities of  
          prospective applicants to law enforcement agencies.  

           The Proposed Broad 'Law Enforcement' Exemption Appears to Be a  
          Very Broad Exclusion for Public Employee Privacy Rights Indeed:    








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          In opposing this measure, various law enforcement organizations  
          request the following broad amendment be added to the measure:

          "This section shall not apply to any position within a criminal  
          justice agency, as that term is defined in section 13101 of the  
          Penal Code, or to any individual working on a temporary or  
          permanent basis in a criminal justice agency whether on a  
          contract basis or on loan from another governmental unit." 

          Under this extremely broad exemption, it would appear to exclude  
          from the bill's privacy protections sworn peace officers  
          carrying weapons, as well as many other public employees working  
          in a criminal justice agency whether on a contract basis or on  
          loan, including such individuals as janitorial staff, landscape  
          and maintenance staff, laboratory technicians, computer  
          programmers, photographers and graphic designers, and  
          administrative staff, including secretaries, typists,  
          accountants and auditors.  Apparently to ensure that criminal  
          justice agencies can appropriately screen applicants in order to  
          protect public safety, the proposed amendment would effectively  
          provide that  any employee  of a criminal justice agency forfeits  
          any right to privacy.  This proposed amendment seeks to rob  
          public employees of their constitutional and statutorily  
          protected privacy rights-all in the name of public safety.  

           The Proposed Exemption Also Very Well Would Be Found to Be Per  
          Se Unconstitutional  :  Not only would the proposed law  
          enforcement exemption reportedly be unprecedented across the  
          country in these kinds of privacy protection laws, it would  
          also, as noted above, potentially be found to be  
          unconstitutional.

          Specifically, law enforcement is seeking an exemption to the  
          public employer prohibition, which specifies that Labor Code  
          Section 980 shall not apply to law enforcement agencies (1)  
          conducting background checks for applicants for employment or  
          (2) in the course of ordinary law enforcement officer conduct  
          investigations.
           
           As noted, the Fourth Amendment provides that "the right of the  
          people to be secure in their persons, houses, papers and  
          effects, against unreasonable searches and seizures, shall not  
          be violated, and no Warrants shall issue, but upon probable  
          cause, supported by Oath or Affirmation, and particularly  
          describing the place to be searched, and the persons or things  








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          to be seized."  (U.S. Const. 4th Amend.)  

          According to the Supreme Court in Katz v. United States, a  
          person has a constitutionally protected reasonable expectation  
          of privacy from an electronic intrusion into a place that is  
          private-an invasion into a constitutionally protected area by  
          federal authorities is presumptively unreasonable in the absence  
          of a search warrant supported by probable cause.  (Katz v.  
          United States (1967) 389 U.S. 347 (concurrence Harlan, J.).)   
          Under the 'reasonable expectation of privacy' test, a person  
          must have exhibited an actual (subjective) expectation of  
          privacy, and the expectation must be one that society is  
          prepared to recognize as "reasonable."  (Ibid.)

          Additionally, the Court noted that the Fourth Amendment protects  
          people, not places.  What a person knowingly exposes to the  
          public, even in his own home, is not a subject of Fourth  
          Amendment protection.  But what he seeks to preserve as private,  
          even in an area accessible to the public, may be  
          constitutionally protected.  (Id. at 351.)  (See United States  
          v. Ganoe (9th Cir. 2008) 538 F.3d 1117, 1127 [finding no  
          reasonable expectation of privacy in personal computer files  
          accessible to anyone using the peer-to-peer filing trading  
          network.].)  (See also United States v. Gines-Perez (2002) 214  
          F.Supp.2d 205, 224-26 [finding no reasonable expectation of  
          privacy in a photograph available on a publicly accessible  
          website.].)   

          In this instance, a prospective employee's or current employee's  
          privacy rights under the Fourth Amendment will be analyzed as to  
          whether an employee has a 'reasonable expectation of privacy.'   
          An employee would not, for example, appear to hold a 'reasonable  
          expectation of privacy' in the content of their social media  
          page (i.e. a post to their Facebook Wall) because they have  
          typically knowingly exposed this content to the public.   
          However, the fact that Facebook, for example, requires a  
          username, and is password-protected, would appear strongly to  
          lean in favor of a court finding that some form of 'reasonable  
          privacy expectation' exists specifically in the 'username and  
          password' itself-which is distinguishable from any social media  
          content available to the public to see. 

          It is true, however, that government employees' Fourth Amendment  
          privacy interests are weighed against the employer's legitimate  
          business interests.  (See City of Ontario v. Quon (2010) 130  








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          S.Ct. 2619, 2632-33.)  (See also O'Connor v. Ortega (1987) 480  
          U.S. 709, 725-26.)  In O'Connor, the Supreme Court held that  
          public employer intrusions on the constitutionally protected  
          privacy interest of employees for non-investigatory,  
                                                  work-related purposes should be judged by the standard of  
          reasonableness under all circumstances.  (O'Connor, 480 U.S. at  
          725-26.)  

          Most recently, in City of Ontario v. Quon, the Supreme Court  
          rearticulated the standard when determining the reasonableness  
          of the government's search of a police officer's text messages  
          in his government-provided pager for the purposes of  
          investigating potential misconduct.  (Quon, 130 S.Ct at  
          2632-33.)  The Court held the search of the text message, which  
          was tailored to investigate whether the text-messaging plan  
          needed to be increased or whether the overages during work hours  
          were personal in nature was reasonable in purpose and scope.   
          (Ibid.)  

          However it also appears that a law enforcement agency's  
          intrusion on a constitutionally protected privacy interest-in  
          this instance a username and password-must be reasonable under  
          all circumstances, given the search's breadth in scope.  An  
          exemption provided for law enforcement to conduct a background  
          check via social media on potential employees would appear to be  
          unreasonable because it would provide law enforcement with  
          overly broad, and completely unfettered access to personal  
          information that is already statutorily protected under the  
          state's Fair Employment and Housing Act, including their sexual  
          orientation, religion, and marital status.  Moreover, access to  
          this protected personal information through gaining the "keys"  
          to the employee's or applicant's personal social media sites  
          would also likely be found to be without any relevant relation  
          to his or her fitness for employment in law enforcement.   
          Indeed, the inadvertent access to this protected information,  
          inherently inseparable from other personal information, would  
          appear to be a direct and serious violation of the state's  
          anti-discrimination laws. 

          Additionally, the sought-after exemption providing for law  
          enforcement agencies in the course of a law enforcement  
          investigation to request or require an employee to disclose his  
          or her username or password would appear to be unnecessary and  
          perhaps confusing.  This is because, under the current statutory  
          scheme in Labor Code Section 980, the law already provides a  








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          broad "investigation exemption," whereby a law enforcement  
          employer would not be prohibited from requesting an employee to  
          divulge personal social media reasonably believed to be relevant  
          to an investigation of allegations of employee misconduct or an  
          employee's violations of the law.  (See Labor Code Section  
          980(c).)  An employee could deny such a request, at which point  
          the law enforcement agency could seek a warrant.

          Finally, it should be acknowledged that law enforcement agencies  
          have existed for hundreds of years before the advent of social  
          media, and they have effectively screened officers and  
          applicants to do a great job protecting public safety.  Existing  
          law permits employers to screen numerous aspects of a  
          prospective employee's background, including screening  
          employees' past civil liabilities, criminal records and securing  
          a full background check-tools that appear to be very sufficient  
          in efforts to protect an employer's interest in hiring a person  
          qualified for the job.

          In conjunction with their broad current authority to conduct  
          background checks and monitor officer conduct, it is therefore  
          reasonable to query, as noted by the bill's privacy group  
          supporters, whether the potential violation of their employees'  
          or applicants' reasonable expectations of privacy is required to  
          effectively accomplish effective screening and monitoring.   
           
          The Requested Exemption is Distinguishable from Existing Law  
          Enforcement Exemptions for Carrying Concealed Firearms  .  Certain  
          classes of persons, such as law enforcement officers are  
          exempted from the operation of the prohibition against carrying  
          concealed firearms, and including certain retired law  
          enforcement officers who during the course and scope of their  
          employment as peace officers were authorized to, and did, carry  
          firearms.  (Penal Code Section 25450.)  These existing  
          exemptions are justified based on the rationale that peace  
          officers in the course of their duty to protect the public  
          should be permitted to carry concealed weapons.  However, unlike  
          the proposed law enforcement exemption, the exemption provided  
          for in Section 25450 to the Penal Code is limited to only peace  
          officers-it does not permit any employee of a criminal justice  
          agency to carry a concealed weapon under the broad banner of  
          'public safety.' 

          The right to privacy guaranteed by the Fourth Amendment of the  
          U.S. Constitution differs significantly from the Second  








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          Amendment guarantee of an individual's right to possess and  
          carry weapons.  Under the Second Amendment, the right to possess  
          and carry a weapon may be reasonably limited, such as  
          prohibitions for certain classes of people, including felons and  
          the mentally ill.  However, under the Fourth Amendment the right  
          to privacy is unyielding, even when the interests of public  
          safety are paramount-the protections of the Fourth Amendment do  
          not fade when one becomes a public employee of a law enforcement  
          agency.  If we were to proceed otherwise, any public employee of  
          a law enforcement agency would effectively forfeit all of their  
          privacy interests.  Indeed, under the theory supporting such a  
          broad privacy exemption from privacy protections for law  
          enforcement, it would appear there are effectively no privacy  
          rights or protections for any one working in law enforcement at  
          all - even those anti-discrimination rights explicitly protected  
          in the state's Fair Employment and Housing Act.   
           
          The Requested Exemption Clearly Appears to Open Up A Potential  
          "Slippery Slope"  :  Exempting a broad number of public employees  
          in law enforcement from the law's privacy protections would also  
          appear to create a substantial risk that such an exemption would  
          inevitably, and likely quickly, lead to many other public  
          employers seeking similar exemptions from the law's privacy  
          protections, such as teachers and social workers, and perhaps  
          many others, on the grounds that many if not most public  
          employees work in jobs that could affect public safety.  It  
          could therefore become very difficult for policy-makers to  
          effectively draw a line where it is clear that a particular  
          public job does not somehow potentially affect the public's  
          health, safety and welfare.  This may be why other states that  
          have similar laws have not created any such exemptions, for once  
          done, drawing - and maintaining - the line would appear to be  
          very difficult.

           Need to Return Bill Back to Committee in the Event of Future  
          Amendment:   Pursuant to the Committee's rules and tradition,  
          should this bill pass and face subsequent amendments the author  
          has agreed to bring the bill back for another hearing and  
          further consideration.  

           ARGUMENTS IN SUPPORT  :  In support of this bill, the Southwest  
          California Legislative Council, a coalition of the Temecula  
          Valley, Murrieta, Lake Elsinore and Wildomar Chambers of  
          Commerce and more than 2,200 represented business, states, that  
          it "is a measure that would encourage job growth through  








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          clarifying employers' duties, or lack thereof, with regard to  
          social media and social networking sites as applied to  
          applicants and existing employees.  This legislation will help  
          position California for economic recovery."

          California Professional Firefighters, the state council of the  
          International Association of Firefighters, representing over  
          30,000 career firefighters and emergency medical personnel  
          statewide, offers its support of AB 25 and believes, consistent  
          with existing provisions under the law, public employers,  
          "including those that employ California's state and local  
          government firefighters," should be prohibited from requiring or  
          requesting an employee or applicant for employment to disclose  
          their personal social media.

          The Privacy Rights Clearinghouse, a nonprofit consumer education  
          and advocacy organization, writes in support of the measure  
          that, "job applicants and employees should be entitled to the  
          same privacy rights for their social media in the public sector  
          as their counterparts in the private sector."

          The American Civil Liberties Association writes in support that:

               Privacy protections need to keep pace with changes to  
               technology.  And, public employees and applicants  
               should not have to give up their right to privacy to  
               keep or get jobs.  Without this legislation, an  
               employer could misuse private information (including  
               sensitive medical information) intended for friends,  
               lovers or spouses that he or she would not normally  
               have access to by asking an employee or applicant for  
               employment for username and passwords to his or her  
               email, Facebook or other personal accounts.  

               In addition, while current law protects against  
               employment discrimination based on a number of grounds  
               including age, sexual orientation, disability or  
               genetic information or for lawful conduct during  
               nonworking hours away from the employer's premises, an  
               employer who has access to employees' or applicants'  
               social media might learn about and improperly use  
               information that was meant to be private or shared  
               only with a select group of people.
           
           The California Teachers Association supports AB 25, emphasizing  








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          its opposition to any public employee exemption, writing:

               Constitutional rights to privacy are violated when an  
               employer demands that a prospective employee provide  
               passwords meant to protect date stored on a computer.   
               The practice of asking interviewees to provide their  
               passwords sets up an incredibly imbalanced sense of  
               trust between employers and staff.  In general, the  
               interview process includes a background check, a  
               request for references, and an interview questionnaire  
               about one's background, record, and experiences.  To  
               ask for a Facebook password implies that the company  
               does not trust you, and ignores the very real and very  
               damaging long-term costs to organizational culture,  
               employee retention, and managerial trust.  

           ARGUMENTS IN OPPOSITION  :  The California Police Chiefs  
          Association (CPCA) wrote the Committee in strong opposition.   
          Amongst other things, CPCA states that AB 25 will undermine law  
          enforcement's ability to screen and monitor the activities of  
          its personnel, writing in part that:

               Persons in law enforcement have positions of  
               incalculable trust and power in our communities:  
               Front-line officers literally have the authority to  
               deprive a person of his/her freedom, use force when  
               appropriate and even take a life under certain  
               circumstances.  Non-sworn personnel have access to  
               information and records of citizens that has the  
               potential of being diverted to inappropriate use.

               It is for these reasons that law enforcement agencies  
               conduct the most thoroughly of scrutinizes prior to  
               hiring a person into their agency.  That scrutiny and  
               oversight continues even after the individual is hired  
               and vested with the range of authority and access to  
               information that is not available to the general  
               public.

               One of the most important scrutiny tools law  
               enforcement uses is to require the applicant/employee  
               to provide his/her social media passwords, or-in the  
               presence of a supervisor-directly access those social  
               media accounts.  Persons who express animus towards  
               elements of society on their social network sites, for  








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               example, are simply not suited to be trusted with the  
               scope of authority of a law enforcement employee.   
               This information is frequently only available on a  
               social network location.

               We believe that California law enforcement operates at  
               a very high level of professionalism.  That  
               professionalism has been achieved in no small part due  
               to the serious pre-screening and on the job scrutiny  
               of the activities and conduct of law enforcement  
               employees.  Unfortunately, Assembly Bill 25 will  
               vitiate a key element of our ability to screen and  
               oversee those persons who are vested with so much  
               power and trust.  

           Prior/Pending Related Legislation  :  AB 1844 (Campos), Chap. 618,  
          Stats. 2012, prohibits an employer from requiring or requesting  
          an employee or prospective employee to disclose the username or  
          password for the purposes of accessing their personal social  
          media account.

          SB 1349 (Yee), Chap. 619, Stats. 2012, prohibits public and  
          private postsecondary educational institutions from requiring or  
          requesting students, prospective students, or student groups to  
          disclose, access, or divulge personal social media.  
           
          REGISTERED SUPPORT/OPPOSITION  :  

          Support

           ACLU
          AFSCME, Local 685
          Association for Los Angeles Deputy Sheriffs 
          California Professional Firefighters
          California Labor Federation
          California Teachers Association
          Consumer Federation of California
          Glendale City Employees Association
          Los Angeles Police Protective League
          Los Angeles Probation Officers Union
          Organization of SMUD Employees
          Privacy Rights Clearinghouse
          Professional Engineers in California Government
          Riverside Sheriffs Association
          Southwest California Legislative Council








                                                             AB 25
                                                             Page  16

          San Bernardino Public Employees Association
          San Luis Obispo County Employees Association
          Santa Rosa City Employees Association

           Opposition

           California Police Chiefs Association
          California Probation, Parole, and Correctional Association
          Chief Probation Officers of California
          California Association of Highway Patrolmen (CAHP)
          Commission on Peace Officer Standards and Training
          California State Sheriffs' Association
           
          Analysis Prepared by  :  Drew Liebert and Rebecca Kramer / JUD. /  
          (916) 319-2334