SB 1484, An Act Implementing Artificial Intelligence Protections For Employees

TESTIMONY OF THE CONNECTICUT HOSPITAL ASSOCIATION
SUBMITTED TO THE LABOR AND PUBLIC EMPLOYEES COMMITTEE

Tuesday, March 11, 2025

The Connecticut Hospital Association (CHA) appreciates this opportunity to submit testimony concerning SB 1484, An Act Implementing Artificial Intelligence Protections For Employees. CHA opposes Sections 1, 3, and 4 of the bill.

Connecticut hospitals and health systems care for patients, strengthen the state’s economy, and support vulnerable communities across the state. Every day, they work to improve healthcare access, affordability, and health equity. Even as they face ongoing challenges, hospitals provide world-class care to everyone who walks through their doors, regardless of their ability to pay. Hospitals also support an exemplary workforce as the largest collective employer in the state, contribute significantly to the state’s economy, and invest in their communities addressing social drivers of health.

SB 1484 establishes multiple requirements for employers related to the use of electronic surveillance and artificial intelligence (AI) systems, including requirements affecting hospitals and health systems. CHA believes the bill is unwise and creates unwarranted barriers to the use of common technologies in a manner that results in overregulating technologies and AI. We urge you to reject the sweeping approach to technology regulation in this bill.

Section 1 of the bill focuses exclusively on the hypothetical impact of everyday electronic monitoring technologies on employees without an adequate assessment of real-world deployments of the technologies that facilitate safeguarding patients, protecting communities, or operating a functioning business. There is no evidence that the current electronic surveillance laws for workplaces are inadequate. Before imposing significant costs and burdens on employers (and in some instances a de facto ban on the use of common technologies, including cameras and GPS devices), there should be a meaningful review with the participation of all affected stakeholders to understand the costs, benefits, and consequences of imposing broad and unnecessary bans on these common and useful everyday technologies.

Further, the language at lines 63-68 that would ban an employer from sharing electronic monitoring data is particularly problematic. That language would mean normal surveillance camera recordings, or normal GPS tracking data, for example, would be considered confidential information that could not be voluntarily shared with lawyers, consultants, contractors, the police, or the news media – in any situation, even if to support an employee – if an employee was involved in the data. We urge the committee to give more careful consideration to the unintended consequences of such broad regulatory overreach.

Electronically stored information that an employer has should not be assumed to be confidential “employee information” unless there is an actual confidentiality need. Connecticut already has laws that protect employee records and privacy and set parameters for electronic monitoring and surveillance notices.

Sections 3 and 4 of the bill contain nearly identical language to that found in SB 2, An Act Concerning Artificial Intelligence, modified slightly and now with a focus on employer-employee issues, as opposed to consumer protections (although the term “consumer” remains in the copying over of the bill language; see for example lines 116 and 235). CHA opposes the unworkable framework for AI regulation found in SB 2 and mirrored in Sections 3 and 4 of SB 1484. The approach taken in SB 1484 applies overregulation to normal business functions. It would significantly disadvantage Connecticut business, across various industries, including healthcare, while simultaneously not providing a reasonable set of employee protections.

CHA supports SB 1249, the Governor’s bill on artificial intelligence, because it balances the need to keep moving forward with core protections that are appropriately tailored to avoid unnecessary interference with current uses or innovation of AI that might otherwise result from overregulation.

Thank you for your consideration of our position. For additional information, contact CHA Government Relations at (203) 294-7301.