SB 4, An Act Concerning Consumer Privacy

TESTIMONY OF THE CONNECTICUT HOSPITAL ASSOCIATION
SUBMITTED TO THE GENERAL LAW COMMITTEE

Wednesday, March 4, 2026

The Connecticut Hospital Association (CHA) appreciates this opportunity to submit testimony concerning SB 4, An Act Concerning Consumer Privacy.  CHA has concerns about the bill as drafted.

Connecticut hospitals make our state stronger by delivering nationally recognized, world-class care, supporting jobs and economic growth, and serving communities across Connecticut.  Every day, hospitals improve access, affordability, and health equity — providing care to all patients regardless of ability to pay.  At the same time, hospitals invest in their workforce and local communities, even as they navigate significant financial and federal challenges.

SB 4 contains a number of unrelated provisions restricting data use and regulating companies that use technology.

Sections 1-9 of SB 4 seek to create a new registration category of “data broker” to be overseen and regulated by the Department of Consumer Protection (DCP).  Unfortunately, the relevant definitions for these sections lack context and are confusing, which makes it difficult, if not impossible, to understand which businesses must register with DCP and what operational changes would be required of those that must register.

When the state regulates technology, it should be very clear and transparent about which businesses are affected by this bill and what activities the bill is intended to regulate.  SB 4 fails to do that.  This is problematic not only because it fails to meet basic due process standards, but it also will fail to protect consumers if it is not transparent and understandable. 

Additionally, the provisions of the bill that seek to interfere with legitimate uses of data for employment decisions as well as provisions relating to safety and security are not sufficiently balanced or clear.  We appreciate that the bill is attempting to curb perceived abuse of data or discrimination that could be perpetuated by certain uses or types of technology.  But there should be more careful consideration from human resources experts, law enforcement, and private security experts about how to best meet those goals without accidentally creating safe harbors for criminals or adopting provisions that allow dangerous behavior to go unchecked.

We look forward to working with the committee to address these issues and concerns. 

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