Legislative Alert: CCPA (7/8/19)
Subject: CCPA
AAF California Club Presidents and AAF Board Members,
The AAF continues to work with our association partners to mitigate the potential harms of the California Consumer Protection Act which is due to go into effect on January 1, 2020.
As it currently stands, one provision of the new law would inadvertently lessen consumer privacy.
The CCPA generally requires that personal information be provided to a consumer or deleted upon request. An exception exists when a business would need to re-identify or otherwise link non-personal information to personal information in order to fulfill the access request.
However, these exceptions do not cover non-identified data that could be considered personal information, like a cookie ID or another ID associated with a browser or device, but not a specific individual. Many businesses rely on this non-identifiable information for advertising purposes, and they intentionally do not associate it with identifiable personal information in order to provide consumers with additional privacy. The CCPA could ironically force businesses to link this non-identified personal information to identifiable personal information, such as an individual’s real name, postal address or email, to fulfill an access request from that individual.
Our industry group has suggested an amendment that would provide a limited fix to this issue while retaining other consumer protections in the CCPA.
We have purchased an ad in today’s print and online versions of the Sacramento Bee explaining our position to California consumers and lawmakers. The online ad links to a website that explains this issue in further detail. Print ad is [below].
We will continue to do all we can to work with our industry partners and lawmakers to ensure that the CCPA protects consumers while allowing businesses to communicate with them in responsible and effective ways.
Please do not hesitate to contact me if you have any questions.
Clark Rector
Executive Vice President-Government Affairs
American Advertising Federation
1101 Vermont Avenue, NW, 5th Floor
Washington, DC 20005
202-898-0089
