NAI Comments on CA Data Broker Registration Regulations

On August 20, the NAI submitted comments on the proposed California Data Broker Registration Regulations to the California Privacy Protection Agency (CPPA).

In Section I, our comments recommend that the Agency define reproductive health care data (RHCD) as sensitive personal information under the California Consumer Privacy Act (CCPA). This clarification would assist both consumers and businesses by making it easier to manage and protect RHCD as listed in California’s data broker registry.

In Section II, we recommend distinguishing between short-term, non-commercial uses of RHCD and precise geolocation (such as de-identifying or aggregating data) versus commercial uses. This distinction would help consumers understand which businesses on the registry are using these types of data for commercial purposes and encourage businesses to limit their processing of such data.

Read the full comments here: