NAI Comments on Colorado Universal Opt-Out Shortlist

On December 11, 2023 the NAI submitted comments on the Universal Opt-Out (UOOM) shortlist recently announced by the Colorado Department of Law (DoL). In summary, the NAI recommends the following with respect to the candidate UOOMs included in the shortlist:

• The NAI supports incorporating specific implementations of Global Privacy Control (GPC) in the initial list of approved UOOMs that meet the Consumer Choice Principle and CPA and Regulations requirements, but not the technical specification itself.
• The NAI opposes OptOutCode’s inclusion in the initial list due to the applicant’s failure to consult with stakeholders, denying them valuable input on its design and implementation. While OptOutCode addresses internet-connected devices, further engagement with industry stakeholders could strengthen a future submission.
• The NAI opposes the inclusion of the Opt-Out Machine in the initial list of UOOMs, citing confusion between UOOM and authorized agent concepts in the CPA. They view it as an authorized agent service, causing duplication and confusion about consumer verification and authorization requirements.