ANA Submits Comments Urging California Attorney General to Clarify Key Provisions of California Consumer Privacy Act (CCPA)

ANA has urged the California Attorney General to clarify several key provisions of the California Consumer Privacy Act (CCPA) to help ensure compliance with the law and enhance consumer privacy. In written comments (available here), ANA voiced its strong support for the underlying goals of the CCPA while identifying priority issues for the Attorney General to address.

“Privacy is an extraordinarily important value that deserves meaningful support in the marketplace,” said Dan Jaffe, Group Executive Vice President of Government Relations for ANA. “As our members prepare to implement the CCPA, ANA encourages the Attorney General to issue regulations to address significant ambiguities in the law.”

“CCPA as drafted could create unintended adverse consequences for consumers and marketers,” said Jaffe. “ANA’s comments identify priority issues that are within the Attorney General’s authority to address through regulations, describe the real-world impact of these issues, and provide suggestions to address them.”

“One of the most important areas we highlighted was the need to preserve the ability of marketers to offer loyalty programs to their customers,” Jaffe stated. “There are conflicting and ambiguous provisions in the law which need clarification; if unaddressed, the law could inadvertently jeopardize the continued use of these discount programs. Loyalty programs allow businesses to maintain and foster positive relationships with consumers. They provide consumers significant benefits in the form of lower prices and access to special offers. We urge the AG to allow companies to continue to offer these programs.”  

Among other suggestions, ANA requested guidance to protect consumers when other individuals and entities make access, deletion, or opt-out requests on their behalf, to provide consumers with granular choices about their data under the law, and to clarify additional terms in the law in ways that benefit consumers’ privacy.

The Attorney General must adopt regulations to implement the CCPA and has requested public comments.

To learn more about ANA and the efforts of the marketing community to protect the responsible use of consumer data in the online marketplace, visit

About the ANA:

The ANA (Association of National Advertisers) makes a difference for individuals, brands, and the industry by driving growth, advancing the interests of marketers, and promoting and protecting the well-being of the marketing community. Founded in 1910, the ANA provides leadership that advances marketing excellence and shapes the future of the industry. The ANA’s membership includes more than 1,850 companies and organizations with 20,000 brands that engage almost 100,000 industry professionals and collectively spend or support more than $400 billion in marketing and advertising annually. The membership is comprised of more than 1,100 client-side marketers and more than 750 marketing solutions provider members, which include leading marketing data science and technology suppliers, ad agencies, law firms, consultants, and vendors. Further enriching the ecosystem is the work of the nonprofit ANA Educational Foundation (AEF), which has the mission of enhancing the understanding of advertising and marketing within the academic and marketing communities.