CCPA RULEMAKING HEADS TOWARD THE FINISH LINE

February 13, 2020

The Association of National Advertisers is encouraged that the revised proposed regulations to the California Consumer Privacy Act (CCPA) provide enhanced clarity surrounding some ambiguous provisions in the law. A number of the changes responded to concerns that ANA and others in the ad community had raised in comments to the California Attorney’s General office.

Nevertheless, the regulations remain significantly unclear in several areas of vital importance to both consumers and businesses. As currently drafted, the proposed rules could significantly undermine consumer loyalty programs such as grocery rewards programs, sandwich punch-card programs, and drugstore cash-back programs in the state of California. Additionally, the proposed regulations’ mandated browser signal provisions would deprive consumers of the ability to make granular choices about business transfers of data. We intend to address these issues as well as a number of others in our forthcoming comment submission to the California Attorney General due on February 25.

The CCPA is a novel, operationally complex, and, in many ways, confusing law. It is essential that the California Attorney General continue to work to provide more clarity to help ensure that consumers are given effective privacy protections and that businesses are equipped to structure systems and practices to provide those protections to consumers. ANA intends to continue to do all that it can to improve this critically important law.

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 Growth 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 nearly 1,700 domestic and international companies, including more than 1,000 client-side marketers and nonprofit fundraisers and close to 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.