The California Supreme Court has interpreted the privacy clause of the State constitution to require that any State intrusion into citizen privacy be justified by a 'compelling interest.' In contrast to the Federal Constitution, the California constitutional amendment provides for a personal right of privacy enforceable against any person or entity that wrongfully violates a protected privacy zone. Evidence indicates that businesses cannot be relied upon to respect employees' privacy rights in the absence of definitive case law or statutory prohibitions. The San Francisco ordinance provides a balanced approach to drug testing, as it provides for testing when there is individualized suspicion that drugs are impairing a particular employee's work performance. 32 footnotes and the appended San Francisco ordinance.