What is an ADMT pre-use notice, and what must it say?

Under the California Privacy Protection Agency's CCPA regulations, a business that uses automated decisionmaking technology to make a significant decision has to tell the person first. The requirement is short to state and easy to get wrong. Wording it is the easy part; the notice has to go out before the technology runs.

The requirement, as written

What the notice has to state

Two things, per the regulations:

• The specific purpose for using the automated decisionmaking technology. Specific is the operative word — a general statement that the business uses technology in hiring is not a statement of the purpose the ADMT is being used for.
• How the individual can exercise the applicable rights, including the right to access information about the ADMT's use and the right to opt out of it.

The regulations stop short of supplying the text. There is no official form and no safe-harbor wording. The language is yours, written or reviewed by your counsel, and it is you who answers for it.

What “pre-use” actually means

The notice belongs where the workflow begins: at or before the point where data is collected for the ADMT purpose, or before data already collected for something else is repurposed for it.

This is the part that fails in practice. A notice that goes out with the rejection, in a weekly batch, or whenever a recruiter happens to remember is not a pre-use notice: the sequence is the requirement itself. Any workflow where the notice depends on someone remembering will produce misses at volume, and nobody will see them until they are asked.

The January 1, 2027 deadline, stated precisely

There are two rules inside the one date, and teams routinely plan around only the first:

• ADMT already used for a significant decision before January 1, 2027 must be in compliance by January 1, 2027.
• ADMT deployed on or after January 1, 2027 must comply before first use — there is no grace period for a tool adopted later.

If you add hiring tools whenever a client asks for one, the second rule is the one that matters. Every new tool arrives with a notice obligation already attached, rather than joining a queue for the next review.

Where this breaks operationally

Three things go wrong repeatedly, and none of them are about the wording:

• The notice went out, but nobody can show which version. Approved language changes. Without a versioned template tied to each send, “what did this candidate actually receive in March” becomes a reconstruction exercise.
• The notice was sent, but not delivered. A bounce, a suppression or a hard failure means the workflow did not end where the team assumed it did. That is only knowable if provider-returned events are preserved.
• The record outlives the tool. Candidate notice records need to be exportable on their own terms, not trapped in whichever system happened to send them.

Common questions

This page is general information about published government requirements, last reviewed August 26, 2026. Requirements change; confirm the current text with the agency and your own counsel before relying on it.