CR Comments on the Fourth Set of Modifications to the CCPA Regulations

Though the California Consumer Privacy Act (CCPA) is designed to protect consumer privacy, Consumer Reports has found that some consumers ran into difficulties when attempting to opt out of the sale of their information under the CCPA. The new proposed rules will help address somethough not allof these problems. To better ensure that consumers are able to exercise their privacy rights, we reiterate our comments submitted in response to the Third Set of Modifications (attached), and additionally, recommend that the AG:

  • Finalize the proposed opt out button design;
  • More clearly require companies that sell personal information to include the opt-out button on their homepages, along with the “Do not Sell My Personal Information” link; 
  • Clarify that if an authorized agent inadvertently submits a request incorrectly, the company must either accept it or inform the agent how to submit it appropriately; and
  • Clarify the definition of sale and tighten the restrictions on service providers, to ensure that consumers can opt out of cross-context targeted advertising.

Consumers’ activity online is constantly tracked, and information about their most personal characteristics sold without their knowledge or consent. At the very least, consumers should be able to effectively opt out of the sale of their personal information to third parties. These reforms, if adopted, will better ensure that consumers are able to do so.