The January 1, 2027 Deadline: California’s ADMT Rules for Employers — Scoping Covered Tools, Building Notices and Opt-Outs, and Documenting Risk Assessments

Alan L. Friel, Partner | Squire Patton Boggs

Alan L. Friel is a Partner at Squire Patton Boggs and Chair of the firm’s Data Privacy, Cybersecurity & Digital Assets Practice, a global group of more than 75 lawyers. He counsels companies on privacy and data protection, advertising technology, artificial intelligence governance, and cybersecurity, and defends them when regulators and plaintiffs come calling. Earlier in his career he served as general counsel, corporate secretary and chief administrative officer of a digital media and e-commerce company.

• Education & Credentials

Mr. Friel earned his Juris Doctor from Northeastern University School of Law in 1991 and his Bachelor of Science from Georgia State University in 1988, and completed the Executive Program in Management at the UCLA Anderson School of Management in 2001. He is admitted in California (1993), New York (2002) and Georgia (2026), and before the Central District of California and the Ninth Circuit. He holds the CIPP and CIPM certifications from the International Association of Privacy Professionals.

• Recognition & Leadership

Chambers USA has ranked Mr. Friel in Band 1 for Privacy & Data Security: Adtech from 2023 through 2026. He was named 2026 Data Privacy Law Expert of the Year in California by Leaders in Law, a Thomson Reuters Stand-out Lawyer from 2022 through 2026, a Los Angeles Times Legal Visionary and a National Law Journal Trailblazer for Media and Advertising Law in 2023. He is listed in The Best Lawyers in America for Advertising Law for 2026-2027 and holds the Martindale-Hubbell AV Preeminent rating.

• Professional Involvement

Mr. Friel founded the IAPP Orange County KnowledgeNet Chapter and formerly chaired the Los Angeles County chapter. He sits on the Executive Committee and Board of the Los Angeles County Bar Association Privacy and Cybersecurity Section, serves on the Law Firm Advisory Board of the Association of Media and Entertainment Counsel, and participates in the Association of National Advertisers Privacy Working Group. He is active in the American Bar Association’s Entertainment, Intellectual Property and Advertising & Promotions Sections, and teaches at Loyola Marymount University School of Law and the UCLA School of Film, Television and Digital Media.

• Experience

Mr. Friel has edited the Privacy and Data Protection chapter of the CCH and Wolters Kluwer Corporate Legal Compliance Handbook since 2007 and serves on the Boards of Editors of Internet Law & Strategy and Cybersecurity Law & Strategy. He co-authored “Making Sense of the Patchwork of U.S. State Consumer Privacy Laws” for the CPI TechREG Chronicle in November 2024, and contributes regularly to the Privacy World blog, Law360 and the Daily Journal.

Michael W. Kelly, Partner | Squire Patton Boggs

Michael W. Kelly is a Partner in the Labor and Employment Practice at Squire Patton Boggs, based in San Francisco with a second office in Palo Alto. He represents employers in employment litigation, collective bargaining and arbitration, and handles wage and hour, discrimination, harassment and retaliation matters, including cases arising under the Railway Labor Act and the WARN Act. He formerly served as managing partner of the firm’s Northern California offices.

• Education & Credentials

Mr. Kelly earned his Juris Doctor cum laude from Case Western Reserve University in 1992, where he was managing editor of the Case Western Reserve Law Review, and his Bachelor of Arts cum laude from Harvard University in 1989. He is admitted in California (2001) and Ohio (1992, inactive), before the U.S. Courts of Appeals for the Fifth, Sixth and Ninth Circuits, and before the U.S. District Courts for the Eastern, Northern and Southern Districts of California, the Northern District of Illinois, the Northern District of Ohio, the Western District of Texas, the District of Nebraska, and the Eastern and Western Districts of Wisconsin.

• Recognition & Leadership

Mr. Kelly has been listed as a Northern California Super Lawyer since 2013, a designation limited to the top five percent of lawyers in the region. He has served as managing partner of the firm’s Northern California offices and sits on the Board of the Squire Patton Boggs Foundation.

• Professional Involvement

Mr. Kelly is a member of the American Bar Association and The State Bar of California. He serves on the Board of Give2Asia, where he chairs the Governance Committee, and on the Board of the United Way of the Bay Area Annual Campaign. He is a former vice chair of Catholic Charities of the East Bay and chaired its 75th Anniversary Campaign, and he has provided pro bono assistance to the Asian Art Museum Foundation.

• Experience

Mr. Kelly has defended a national distribution company in approximately 70 federal class actions and advised a multinational corporation through an executive management reorganization. His practice spans single-plaintiff and class litigation, labor negotiations and arbitrations, and the employment consequences of restructurings and workforce reductions. He has participated in the U.S. Secret Service Electronic Crimes Task Force.

Sammuel Kim, Associate | Squire Patton Boggs

Sammuel Kim is an Associate in the Data Privacy, Cybersecurity & Digital Assets Practice at Squire Patton Boggs in New York. He builds and strengthens data privacy compliance programs, advises on federal and state privacy law obligations, conducts diligence and negotiates transaction terms involving personal data and artificial intelligence, and supports clients on cybersecurity preparedness and incident response. His clients span financial services, healthcare, technology, retail and e-commerce.

• Education & Credentials

Mr. Kim earned his Juris Doctor from Vanderbilt University Law School in 2022 and his Bachelor of Science cum laude from Fordham University in 2019. He is admitted in New York (2022) and the District of Columbia (2023).

• Recognition & Leadership

Mr. Kim serves on the Pro Bono Leadership Council of the City Bar Justice Center for the 2025-2026 term. He co-presented “Defining ‘Reasonable Security’ Standards” for myLawCLE in January 2026, addressing cybersecurity threats, cross-border data transfers and artificial intelligence compliance.

• Professional Involvement

Mr. Kim devotes significant time to pro bono representation of veterans, small businesses and nonprofit organizations, and participates in the City Bar Justice Center’s pro bono leadership work.

• Experience

Mr. Kim advises on data privacy compliance under US federal and state law, including consumer rights, notice obligations and vendor management. He conducts privacy and artificial intelligence due diligence in corporate transactions, negotiates data protection terms, and counsels clients on consumer protection exposure. He also assists with cybersecurity preparedness assessments and incident response across regulated industries.

SESSION 1 – What the Rules Actually Cover: ADMT, Significant Employment Decisions, and the Human-Review Exit | 2:30pm – 3:30pm

This session settles the scope question that decides everything else. The California Privacy Protection Agency’s automated decisionmaking technology regulations took effect January 1, 2026, but businesses already using ADMT have until January 1, 2027 to comply — and the threshold question is whether a given tool processes personal information and uses computation to replace, or substantially replace, human decisionmaking for one of the significant employment decisions the regulations name: hiring, allocation or assignment of work, compensation, promotion, demotion, suspension, and termination. Attorneys will learn how to apply the ADMT definition to resume screeners, scoring and ranking tools, scheduling and productivity systems, and interview analytics; when meaningful human review keeps a tool outside the regulations, and what the reviewer must understand and be able to override; which employers are covered under the CCPA business thresholds, and how the rules reach applicants, employees, and independent contractors; and how these obligations stack on the Civil Rights Council’s FEHA automated-decision-system regulations that have applied since October 1, 2025.

BREAK | 3:30pm – 3:40pm

SESSION 2 – Building the Compliance File Before January 1: Notices, Opt-Outs, Access, Risk Assessments, and Vendor Contracts | 3:40pm – 4:40pm

This session turns scope into deliverables, working backward from the January 1, 2027 deadline. Compliance here is documentary — a pre-use notice written in plain language, at least two opt-out methods or a properly invoked exception, a process for answering access requests, a completed risk assessment for every covered use, and vendor contracts that make all of it possible — and much of that record must exist before the first covered processing occurs, not after a complaint arrives. Attorneys will learn what a pre-use notice must say and when it must be delivered to applicants and current employees; how to choose between offering an opt-out and relying on the human-appeal or evaluated-use exceptions; how to build the risk assessment record, including completion for pre-existing processing by December 31, 2027 and the first attestation to the CPPA by April 1, 2028; and how to negotiate vendor terms covering bias testing, technical documentation, audit rights, and indemnification.