San Diego public comment on California Consumer Privacy Act brings 4 comments, more technical proposals

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The California Attorney General public comment tour on the California Consumer Privacy Act (CCPA) regulations came to the California State University San Marcos to hear from concerned organizations and companies.  About 40 people were in attendance, but only 6 offered comments.   While the numbers were not overwhelming, the comments were more specific and technical than the 14 offered in San Francisco.

Another representative from the digital advertising industry came and offered concerns regarding loyalty programs, and consumer disclosures:

  • Loyalty programs should not be considered discriminatory pricing
  • Regulations should contain safe harbors to allow service providers and advertisers to rely on written representations of efforts to obtain consents from their customers and publishers (and vice versa).
  • Regulations should clarify what disclosures required so as to avoid what they construed as requiring individualized privacy policies to comply.
  • Personal Data should not include consumer behavioral inference data (a differing opinion was offered by consumer-oriented commenters in San Francisco)
  • Personal Data should be narrowed as any data can be associated with an individual if configured to be that way.
  • The definition of consumers and households should be narrowed to exclude employment data.

Two consultants with a technology background strongly recommended that California follow GDPR precedence in narrowing the inclusion of IP Addresses and MAC Addresses as Personal Information unless it is combined with other data (most EU countries follow this interpretation except the Netherlands).

They also echoed earlier comments recommending that the regulations use GDPR, NIST and ISO standards as guidance for definitions and standards.

Finally a representative from the California Consumer Attorneys expressed frustration that recent amendments to the CCPA eliminated many private rights of actions and encouraged the Attorney General’s office to enforce where they could once the regulations are fully normalized.

The comments were far more specific than in San Francisco, and referred to specific sections.  The next hearing is in Riverside January 24.

 

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