Re: [Secdispatch] CCPA Do-Not-Sell

[Sebastian Zimmeck <[e-mail]>]

Indeed, from a technical standpoint the implementation of a header field is
straightforward. Though, there are related policy implications. Given the
broad scope of what is considered a sale per the CCPA, especially, a lot of
data collected by ad networks would be subject to Do-Not-Sell. Also, it
would be nice to create a solution going beyond the browser, particularly,
covering mobile apps.

Best regards,

Sebastian

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On Fri, Mar 27, 2020 at 3:28 PM Benjamin Kaduk <[e-mail]> wrote:

> On Sat, Mar 21, 2020 at 08:08:40PM -0400, Sebastian Zimmeck wrote:
> > At the beginning of this year the California Consumer Privacy Act (CCPA)
> > became effective. In addition to the rights of data access and deletion,
> > this new privacy law gives consumers the right to opt out from the sale
> of
> > personal information. A "sale" is understood broadly and likely covers,
> for
> > example, a website or app disclosing location data or device identifiers
> to
> > an ad network for purposes of monetization. Now, the most recent
> regulations
> > to the CCPA
> > <
> https://www.oag.ca.gov/sites/all/files/agweb/pdfs/privacy/ccpa-text-of-second-set-mod-031120.pdf
> ?>
> > published
> > by the California Attorney General specify that automatic signals
> > communicating a user's decision to opt out must be respected. Here is the
> > relevant language:
> >
> > "If a business collects personal information from consumers online, the
> > business shall treat user-enabled global privacy controls, such as a
> > browser plugin or privacy setting, device setting, or other mechanism,
> that
> > communicate or signal the consumer’s choice to opt-out of the sale of
> their
> > personal information as a valid request ... ."
> >
> > I am interested in setting up a working group on such device controls.
> The
> > Do-Not-Sell signal could be similar to a Do-Not-Track (DNT) signal.
> > However, the difference is that recipients of the DNT signal were not
> > required to comply with the signal. Rather, they only needed to *say*
> > whether they would comply; per the California Online Privacy Protection
> Act
> > (CalOPPA).
> >
> > Also, the CCPA may have substantial impact beyond California as some
> > companies, e.g., Microsoft, already made clear that they would apply the
> > CCPA to all consumers in the US.
> >
> > It would be great to get a discussion started ...
>
> It's not really clear to me how much discussion is needed...
> if one assumes that you're just considering a HTTP header field, then the
> only technical question I can think of is whether there's intended to be
> some level of richness of expressivity vs. a boolean signal "don't sell my
> data".  At that point it is mostly a matter of writing down the expected
> semantics (the header field registry requires only Expert Review for
> allocations).
>
> -Ben
>
>