The final implementing regulations take effect immediately. The OAL approved the final version along with an updated Addendum to the Final Statement of Reasons. Code, § 1798.130, subd. Although the record-keeping requirement in section 999.317, subsection (b), applies to all requests received, including those the business denies, the disclosure to the consumer required here is necessary to dispel any assumption that granting a request to delete will also delete any record of the request. Code, § 1798.140, subd. If the business treats a request as properly received, the request proceeds through its designated CCPA-request process. At long last, though, the final … Because Civil Code section 1798.120, subdivision (b), requires a business that sells consumers’ personal information to third parties to provide consumers with notice of their right to opt-out of the sale of their personal information, the converse is also true: if the consumer has not been provided with notice of their right to opt-out when the business collected their personal information, the business cannot sell that consumer’s personal information. This modification ensures that businesses expediently address consumer requests and prevents excessive wait times for responses. %PDF-1.6 %���� While not surprising, the CCPA provided guidance that would be useful for companies like Apple and Google that have growing biometric security face scans used to open phones and other devices — those businesses will not be required to disclose this technical data in a response to a request to know, but must acknowledge they have the data. The regs attempt to reconcile the amendments as well as to provide guidance on the rights and obligations of businesses, service providers and third parties under the CCPA. Furthermore, this modification benefits consumers by ensuring that they can make discrete choices about the sale of their personal information while still enjoying the ease and reduced friction of not having to submit separate requests to opt-out on multiple websites or applications. The initial proposed definition of “household” has been modified to “a person or group of people who: (1) reside at the same address, (2) share a common device or the same service provided by a business, and (3) are identified by the business as sharing the same group account or unique identifier.” This change was made in response to comments that the initial proposed definition of “a person or group of people occupying a single dwelling” was overly broad. Subsection (a)(5) concerns restrictions on a business’s use of a consumer’s personal information for purposes other than those disclosed in the notice at collection. It benefits businesses by reinforcing and streamlining their compliance with the data broker registry law and the CCPA. The subsection also adds the term “previously collected.” This change is necessary to clarify that the subsection applies when a business seeks to use previously collected personal information for a use that is materially different than what was previously disclosed to the consumer, not for new personal information that it seeks to collect. The timing of when this CCPA guidance was written is important — these opinions were being written while massive amounts of mobile location data from the public was being bought, sold, and shared under the guise of consumer protection, and with the NAI and IAB advertising industry groups both blessing the practice of selling existing user mobile location data to support COVID tracking efforts. There is a long history of browsers, publishers, and advertising companies trying to agree on global opt-out signals, and CCPA urges this process to continue and for consensus to be made so that consumers can opt-out via global privacy controls. A few highlights from the final CCPA regulations: Service providers: Per the California Attorney General’s Final Statement of Reasons, a service provider that processes information in breach of the provisions of the agreement between the “business” and such service provider is subject to direct enforcement by the Attorney General, even if the business is not inclined to enforce. (CalOPPA), the OAG has reviewed numerous privacy policies for compliance with CalOPPA, which requires the operator of an online service to disclose, among other things, how it responds to “Do Not Track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about their online activities over time and across third-party websites or online services. The final draft (issued August 14, 2020) incorporates some relatively minor changes that the OAG submitted as part of its final rulemaking package, as summarized in its addendum to the final statement of reasons.In addition to generally “non-substantive” edits … Subsection (b)(1) has been modified to add that a business that collects personal information through a mobile application may provide a link to the notice within the application, such as through the application’s settings menu. Thus, comments that propose simply updating an online privacy policy or providing notice without explicit consent for material changes to a business’s use of personal information would not serve the purpose of section 1798.100, subdivision (b). (t)(2)©.) Subsection (d) requires a business that collects personal information online to treat user-enabled global privacy controls as a valid request to opt-out. This change is necessary to avoid possible confusion about how to calculate the 45-day requirement. Indeed, the term “business purpose,” when used in the statutory text, contextualizes why a business discloses personal information to a service provider or third party, not the universe of possible ways a service provider could use that information. June 3, 2020 – Alerts By Odia Kagan. Second, the sentence “At least one method offered shall reflect the manner in which the business primarily interacts with the consumer, even if it requires a business to offer three methods for submitting requests to know” has been deleted. Code, § 1798.140, subd. The comments also contended that many archived or backup systems do not allow specific, targeted deletions, and thus it would not be technically feasible to delete a particular consumer’s information when the archive or backup system was accessed or used. It also benefits businesses, particularly smaller businesses that lack privacy resources, by clarifying the information they must provide to consumers. Civil Code section 1798.140, subdivision (v), defines a “service provider” as one who “processes information on behalf of [the] business” that provided the personal information, pursuant to a contract that prohibits “retaining, using, or disclosing the personal information for a commercial purpose other than providing the services specified in the contract.” Relatedly, a business does not “sell” personal information when it transfers that data to a service provider, provided that the service provider does not “collect, sell, or use the personal information of the consumer except as necessary to perform the business purpose” of the business that provided the personal information. Furthermore, requiring explicit consent puts the consumer in the same position they would have been had the material change been disclosed during the consumer’s first engagement with the business. In the context of an online service, such as a mobile application, the CCPA defines “homepage” as “the application’s platform page or download page, a link within the application, such as from the application configuration, ‘About,’ ‘Information,’ or settings page, and any other location that allows consumers to review the notice . (b)(5).) This modification is necessary to clarify that a business has discretion to provide a link directing consumers to the notice in lieu of including the actual language of the notice in the application’s settings menu. . This section of the Reasons will need more clarification but I’ve been waiting for some part of the CCPA guidance that could apply to how some businesses upload additional User Data to Google Analytics, and associate that data with UserIDs shared between the business and Google — these match tables are used to improve an understanding of marketing funnels, KPIs, and profitability — and are certainly for a “commercial purpose” and provide valuable new data and context for both the business and Google. What the CCPA guidance makes clear, and this should raise red flags for any organizations who took guidance from NAI and IAB on this issue and executed sales of existing user data, is that the CCPA guidance now makes it clear that organizations who provide SDK services to apps, and any app providing data for COVID tracking, need to provide a “‘just-in-time’ notice summarizing those categories of information that a consumer would not reasonably expect to be collected..”. Although it is anyone’s guess when the final regulations will be published, the Attorney General’s office published its last round of modifications two weeks after the written comment period ended. 21.) The subsection also includes an example that illustrates this requirement and provides guidance as to what may be considered a purpose that a consumer would not reasonably expect. Key changes to the final regulations This is based on the OAG’s expertise in this subject area. Household Data Access & Deletion requests are going to be challenging for some organizations, and several aspects of the CCPA guidance seems to be aimed at discouraging “Verification by IP Address” for Access/Deletion requests — and basically organizations need to not only account for household requests (group requests), but also come up with their own internal Trust & Safety solutions to reduce the likelihood of a household guest, Airbnb renter or some other temporary occupant taking advantage of an unsafe access/deletion process. The subsection now prohibits a service provider from retaining, using, or disclosing personal information obtained in the course of providing services except to provide those services in compliance with the written contract for services and in four other limited circumstances. h�b```�E,|Q� cb�H��������x��1�10T>��|@�� �!�u����'�gȷ�1Oml;���G��A܇k�Ӿ��V�t�9;\Hf�w��Jb}�$�(y`�� QvVf�ճ��:T�������� Even in defining the term “service provider,” the CCPA makes clear that a business’s disclosure of personal information must be for a business purpose that is stated in the parties’ written contract. As stated in the ISOR, this subsection is necessary because without it, businesses are likely to reject or ignore tools that empower consumers to effectuate their opt-out right. Throughout CCPA and the guidance from the California Attorney General’s office, there are mentions of “households” — these are groupings of individuals, sometimes related to each other and other times just living together, who may have overlapping data or an interest in restricting access to their data from other members of the household. Former subsection (f), regarding the proposed opt-out button, has been deleted in response to the various comments received during the public comment period. Code, § 1798.140, subd. …, Businesses should create templates for customer support, and are required to provide assistance to consumers who may be unaware of the businesses’ “designated method for submitting CCPA requests.”. Subsection (k) was formerly subsection (h) and has been renumbered. (Bus. It benefits consumers by providing them with information to make privacy decisions while protecting them from the harms that could result from the unauthorized disclosure of this sensitive personal information. For a full list of changes along with brief explanations, please refer to the AG’s newly issued Addendum to Final Statement of Reasons. (Civ. Mobile apps will be able to include a shorthand reference in their menu and provide links to read more about how the business collects personal information, instead of any required length or specific text. Finally, subsection ©(3)(d), which requires the business to describe to the consumer the categories of records that may contain personal information that it did not search, is necessary to provide transparency to consumers. (q)(5), 999.308, subd. The California AG has now released the final CCPA regulations, as approved by the Office of Administrative Law (OAL). And it seems that some businesses were advocating to the California Attorney General that they should be able to merely update a notice / TOS / Privacy Policy, and that CCPA doesn’t provide the OAG authority to strengthen requirements and require consumer-consent for a new data collection purpose. & Prof. Code, § 22757, subd. The final version is essentially identical to version three of the regulations released in early March 2020. In a press conference discussing the regulations, the AG’s Office stressed that the draft of the proposed regulations and Initial Statement of Reasons are among the best resources explaining the CCPA’s expected implementation. The requirement benefits consumers by making notices more conspicuous in instances in which their personal information is being collected for purposes not reasonably expected. The final regulations are substantially similar to the most recent draft regulations issued in June, with a few notable changes discussed below. I’ve been building and optimizing marketing and analytics stacks for 13+ years for politicians, businesses, my own startups, and client projects — with the last ~8 at my firm Victory Medium. ]Z����ܾ��=��@FQ%�]�/ŀĭ%ݱ����&f/�]��v��9�I�n ��փ�=��op���P�b����X��-�� ��b2��ɱ %f;�$���8/�z�&B:n�C�m�&f�g ���pϖ��L]W�p��1 �����u%Y��>J�1H� J ��vG3� q�EPD ̓h`�`��`�h ɀ2 � ,@.��h�Vo�@��3i�Uu�t1�A��M:����@.����&�8� f�a`�� 9`�đ �`�%@�6u���-@Z �E���f��X���T� Ť�����#�n��jK�ܻ�m�3H��2�C2I#{��^��@�����3�f����:��,��b� 0 �2I By modifying the regulation to limit the compliance obligation for deleting personal information on backup systems to when those systems are restored or used for a sale, disclosure, or commercial purpose, the regulation lessens the burden on businesses. (See Civ. There are several clarifications for Service Providers, and there seem to be additional restrictions and clarifications that will apply to any businesses that acquired user data as part of a Service Provider relationship — those businesses are not allowed to retain or use that personal information for its own business purposes. Subsection (d)(5) has been modified in three ways. Categories of data sources and the types of entities that collect data have been expanded to include and require more specificity, with several new entity definitions including, “ advertising networks, internet service providers, data analytics providers, operating systems and platforms, social networks, and data brokers.”. This Reason seems to be another section that will eventually encourage innovation and new privacy products. This is probably a good but overly broad opinion — it feels like a potential loophole for massive data collection companies that are partnering with governments, and building profiles on ordinary Americans. (a)(4)©.) For example, the FTC has long expected that companies should obtain affirmative express consent before using consumer data in a materially different manner than claimed when the data was collected. There’s an important balance between reducing consumer rights and ensuring businesses aren’t overly burdened — the current CCPA guidance seems to provide a loophole for businesses that can’t access an archived or backup system to delete user data. There are several comments in the California Attorney General’s “Final Statement of Reasons” for CCPA that clarifies important rights and responsibilities under CCPA. Like businesses, public and nonprofit entities outsource operational needs through service providers that essentially perform tasks as if the public or nonprofit entity was doing the task in-house themselves. Unfortunately, while the Addendum to the Final Statement of Reasons explains what changes were made, it provides no detail as to why. As discussed in our prior post , on Friday, August 14, 2020, the California Office of Administrative Law (OAL) approved the California Office of the Attorney General's (OAG) final CCPA regulations and filed them with the California … Written comments may be submitted before the final CCPA regulations are issued by December 6, 2019. Thus, the intent of the CCPA is to prohibit a service provider from using personal information collected from one business for its own business purposes or to then provide services on behalf of a different business. Code, § 1798.185, subd. Inherent in this authority is the ability to adopt regulations that fill in details not specifically addressed by the CCPA, but fall within the scope of the CCPA. If the business declines to do so, the business can simply provide the consumer with a pre-formulated response with information on how to submit the request and remedy deficiencies. The California Consumer Privacy Act (CCPA)is going to be enforced starting on July 1, 2020 having gone into effect at the start of 2020 — and new guidance from the California Attorney General should quickly become the focus of any digital organizations with significant amounts of user data. It also reduces the burden on businesses by streamlining the communication methods for receiving and confirming receipt of requests. Another way to put this, a business can let you Request to Delete your data, and require that you submit pieces of information to confirm your identity that the business *did not have before you submitted the form* and then the business can hold that information for 24 months. Financial incentives: The rules relating to financial incentives have been a source of confusion and debate throughout the rulemaking process. Under the CCPA guidance, businesses that “substantially interacts with consumers offline may satisfy the requirement that it use an offline method to provide notice to consumers by posting signage directing consumers to ‘where the notice can be found online.’”. As already stated, the CCPA gives the OAG authority to promulgate regulations that further the purposes of the CCPA. (v).) Consumers exercising their rights to make requests under the CCPA should not be hindered by unreasonable delays, and 45 calendar days provides businesses with sufficient time to provide the required response, especially considering that they can extend the time to respond by another 45 calendar days. (See ISOR, pp. This change is also necessary to encompass both temporal proximity, such as in online data captures, and physical proximity, such as near a cash register at an in-store location where collection is taking place. This prohibition is consistent with how the CCPA defines and regulates the disclosure of consumer personal information to service providers and service providers’ use of that information. This change will benefit businesses by providing further guidance on how to provide notice to consumers and will benefit consumers by making the notice more apparent when personal information is collected. (Civil Code § 1798.140, subds. Both IAB and NAI encouraged members to share any data valuable against fighting COVID in the Senate hearing that was not on video, via their written statements for the hearing “Enlisting Big Data in the Fight Against Coronavirus.”, It’s clear that organizations who buy/sell/share user data, need to get much more serious about user consent, the categories of collection they undertake, and their potential legal exposure from not requesting user consent for a material change in collection purpose — and the CCPA guidance makes it clear that “simply putting up a new notice on a website after a consumer has already provided personal information, when that consumer may be unlikely to revisit the website (and even more unlikely to revisit the notice), is not meaningful consumer notice.”. including, but not limited to, before downloading the application.” (Civ. .. Subsection (c ), which requires a business to consider the methods by which it interacts with consumers when determining which methods to provide for submitting requests to know and requests to delete, has been modified in four ways. The regulation also benefits businesses by providing clear guidance regarding when they must provide a just-in-time notice on a consumer’s mobile device. Code, § 1798.110 [merely requires the disclosure of “categories of third parties” with whom a business shared personal information].) There are several dozen niche issues throughout CCPA and the Final Statement of Reasons that were not discussed in this already, massive blog post. Some comments claimed operational difficulties in complying with opt-out requests within 15 days, particularly if requests are received during the holidays, and asked that the regulation at least be modified to 15 business days, not calendar days. The CCPA Reasons from the CA AG also explicitly say why a business can’t just continue to update their data policy notices for new purposes or data sales, because as most people know about user behavior, people don’t go back to revisit privacy policy, terms of service, or data policy webpages, if they even review those pages once. (See Civ. In those instances, the business must provide a just-in-time notice summarizing those categories of information that a consumer would not reasonably expect to be collected and a link to the full notice at collection. Furthermore, simply putting up a new notice on a website after a consumer has already provided personal information, when that consumer may be unlikely to revisit the website (and even more unlikely to revisit the notice), is not meaningful consumer notice. The data broker registry addresses this gap by publicly identifying specific businesses that may be selling the consumer’s personal information. In what is potentially one of the more important sections of the CCPA Reasons, the California Attorney General makes it clear that if a business uses consumer data for “any commercial purpose” there will be a “general fairness principle to ensure that a business that is not able or willing to disclose personal information to the consumer cannot profit or commercially benefit from that personal information.”. This regulation offers consumers a global choice to opt-out of the sale of personal information, as opposed to going website by website to make individual requests with each business each time they use a new browser or a new device. These modifications also provide more guidance to businesses concerning the information they are required to provide to consumers, especially when responding to a request to know. This modification balances the CCPA’s intent to provide rights and transparency to consumers with the burden on businesses, including potential security concerns. There are several sections in the CCPA Reasons about providing discounts to consumers for their data. The majority of businesses disclose that they do not comply with those signals, meaning that they do not respond to any mechanism that provides consumers with the ability to exercise choice over how their information is collected. It is necessary to preserve the consumer’s ability to object to the use of their personal information for new purposes, particularly because the business already has their personal information. By requiring businesses to describe categories of third parties in a manner that is easily understood by consumers, these modifications implement a performance-based approach. “Categories of third parties” has been clarified to mean types “or groupings of third parties with whom the business shares” personal information, rather than “types of entities that do not collect personal information directly from consumers.” The definition has also been modified to require a business to describe its categories of third parties “with enough particularity to provide consumers with a meaningful understanding of the type of third party.”. Subsection (e) was added to state that a business cannot sell personal information it collected during any time it did not have a notice of right to opt-out posted unless it obtains the consumer’s affirmative authorization for the sale. Thus, the modifications make the language of the regulation consistent with the language in the CCPA and harmonize this subsection with section 999.306, subsection (d). It benefits businesses by clarifying requirements for businesses and giving them the flexibility to shorten the language included in the actual application. Allowing consumers the opportunity to consent to this further use is consistent with the CCPA’s goal of fairness, choice, and control. In light of the comments received from the public, the OAG further supplements its statement of reasons in support of subsection (a)(5) as follows. Code, § 1798.140, subd. These restrictions are necessary because the consumer could have reasonably relied on the notice when interacting with the business and allowing it to collect their personal information. Presumably, the Attorney General will now publish final regulations and a final statement of reasons (instead of another round of modifications). Code, § 1798.140, subd. 0 These sections were probably important to include, but these Service Provider exemptions for businesses working with Public and Nonprofit entities will need to parsed, and potentially certain Government Data Brokers not given this same blanket exemption. These changes appear in the Attorney General’s Addendum to Final Statement of Reasons, which can be found here. The DOJ basically dumped this question directly onto businesses by relying a lot on standards, instead of rules, for verifying consumers. Subsection (a)(5) is consistent with the language, intent, and purpose of the CCPA to provide consumers with greater control over their information and meaningful ability to exercise their CCPA rights. Brief disclaimer: I’m not a lawyer — i’m a longtime digital strategist who has a significant interest and experience with user data privacy frameworks (i’ve also got my CIPP/US privacy certification from the IAPP). This subsection is necessary to provide transparency into business practices that defy consumers’ reasonable expectations, particularly when those uses are not reasonably related to an application’s basic functionality. Without this regulation, service providers used by public and nonprofit entities may be required to disclose or delete records in response to consumer requests because they may constitute businesses that maintain consumers’ personal information. The final implementing regulations are similar to the The clarification of “business days” addresses business holidays and lessens the burden on businesses. (Civ. The proposed final rules substantively are the same as the draft rules released for public notice on March 11, which we summarized previously here. Subsection (d) has been modified to provide further guidance and clarification for the definition of “categories of sources,” which is used throughout these regulations. Businesses should provide assistance to consumers who may be unaware of the business’s designated method for submitting CCPA requests or may have made a mistake by contacting the business via some other method. The final implementing regulations are similar to For many of these organizations, there were concerns about restrictions being placed on their online forms — but it seems that a business will not be limited by the fields they request from people or authorized agents to complete the submissions. In conjunction with the release of the final version of the regulations, the AG released an Addendum to Final Statement of Reasons explaining that it had (1) withdrawn certain provisions for additional consideration and (2) any changes to the text of the June 1, 2020 regulations were “non-substantive” and for “accuracy, consistency, and clarity.” Subsection © thus accurately reflects the CCPA’s requirement that service providers act on behalf of a business by processing information to further the business’s specific business purpose and not for the service provider’s own business purposes. The record includes, among other documents, the final text of the proposed CCPA regulations and the Final Statement of Reasons, which summarizes and responds to each public comment received and explains the bases for the regulations. Code, §§ 1798.185, subd. 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