Privacy Investigations Lack Due Process Protections

The Division receives broad investigative and adjudicatory powers over privacy complaints (11(1)(d)-(e)) without explicit procedural safeguards for investigation subjects. The provision does not specify whether journalists, whistleblowers, or others facing privacy investigations receive notice, opportunity to respond, or clear evidentiary standards before the Division makes binding liability determinations. Given the bill's expansive definitions of private facts (45) and confidential information (52), this procedural gap could enable investigations that chill legitimate reporting on government misconduct, with judicial review available only after administrative proceedings conclude (60).