The California Consumer Privacy Act, due to take effect in January next year, will trigger significant changes and review of existing relationships between businesses and their vendors and service providers.

Writing in the current issue of Admap, the subject of which is Data Ethics, Gerard M. Stegmaier and Mark Quist of law firm Reed Smith, advise businesses to plan for and anticipate the consequences of the CCPA (which has a low threshold for revenue and information collection requirements) and laws like it, taking stock of the personal information they collect.


“They need to prepare for a world where they and their vendors and suppliers will be increasingly accountable,” the authors write. (For more, read the full article: Navigating the CCPA: Anticipating the immediate impact and long-term pitfalls for the advertising industry.)

While the CCPA echoes the EU’s General Data Protection Regulation (GDPR) in many respects, in terms of how it defines personal information as that which can reasonably be linked with an individual consumer, “it notably expands this broad scope of application by also including information collected about a particular consumer’s household and any ‘[i]nferences drawn . . . to create a profile about a consumer’.”

And while the GDPR distinguishes controllers from processors of personal data, the CCPA focuses on (regulated) businesses’ relationships with “service providers” and “third parties”.

California residents will be able to opt out of the sale of their personal information or request that businesses delete their personal information; if they do so in large numbers, then “brands may find that online advertising platforms that rely heavily on third-party data will be of somewhat diminished utility”.

But personalized advertising is unlikely to disappear, the authors argue, even if the risks and compliance costs increase.

“First-party data collectors will have an increased incentive under the CCPA to either directly perform marketing and analytics functions or impose very strict control on partners’ and vendors’ use of data,” they note.

“This process may benefit large, integrated companies that perform many key data processing functions or who can negotiate favorable terms from vendors and suppliers.”

This issue of Admap features a selection of articles by thought leaders from across the globe, including Bob Hoffman and Ann Cavoukian. WARC subscribers can access the deck – Data ethics – which summarises the expert advice from contributors and key considerations on this important topic.

Sourced from Admap