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)'s mission is to drive growth for marketing professionals, for brands and businesses, and for the industry. Growth is foundational for all participants in the ecosystem. The ANA seeks to align those interests by leveraging the 12-point ANA Masters Circle agenda, which has been endorsed and embraced by the ANA Board of Directors and the Global CMO Growth Council. The ANA's membership consists of more than 1,600 domestic and international companies, including more than 1,000 client-side marketers and nonprofit fundraisers and 600 marketing solutions providers (data science and technology companies, ad agencies, publishers, media companies, suppliers, and vendors). Collectively, ANA member companies represent 20,000 brands, engage 50,000 industry professionals, and invest more than $400 billion in marketing and advertising annually.