CCPA Data Broker Email Template
In our most recent post, we shared our experience trying to submit our CCPA data requests to data brokers using Vael as our “authorized agent”. If you didn’t read our last post, this process was a complete nightmare for a multitude of reasons. Although Vael met all of the criteria to operate as a legitimate authorized agent under CCPA and provided data brokers with all of the necessary information needed to verify our (Vael) and the consumer’s (Michael and I’s) identity, most data brokers rejected Vael’s CCPA data requests. In most cases, data brokers used “identity verification” as their reasoning not to process Vael’s CCPA data request, then we’re able to side-step Vael as the authorized agent and communicate directly with the consumer. Thus, placing more burden on the consumer who is merely wanting to exercise their rights. Again, the authorized agent portion of CCPA seems promising on paper, but is not effective in reality.
What is a Data Broker?
California Civil Code § 1798.99.80 defines a data broker as a business that knowingly collects and sells to third parties the personal information of a consumer with whom the business does not have a direct relationship, subject to specified exceptions. As referenced in our previous post California’s Attorney General has a Data Broker Registry on their website, which is a list compiled of all data brokers subject to CCPA, the data broker’s email address, website URL, and a description of how to submit your CCPA data requests to these data brokers. Although, the registry organizes data broker information in a manner that is more accessible, this is still not an ideal process. The burden is once again placed back onto the consumer to take the time and submit CCPA data requests to the over 400 data brokers listed on the registry. Ultimately, the inconvenience disincentivizes privacy, which means data brokers win. If you (the data broker) are in the business of collecting and selling people’s personal information to third parties, the current process works well in your favor.
The tricky thing with data brokers is that these are companies you have likely never heard of or knowingly come across on the internet. It’s not like you (as a consumer) are ever going out and actively searching for the names of these companies. For a little bit of humor/horror, I have picked a few data broker company names registered with the California Attorney General’s office. Note: these are real names, I could not make this up!
- People Finder
- Spy Dialer
- Ad Colony
- True Influence
- Person Find
- Traackr
- Searchbug
- Complete Mailing Lists
- People Data Labs
- Deeptrace
If the above mentioned company names don’t raise some red flags about what information of yours might be out there, then I don’t know what will.
How Can I Exercise My Data Rights with Data Brokers and What Rights Should I Exercise?
At this point, you might be wondering how can I exercise my CCPA data rights with data brokers? Unfortunately, this process is not the easiest under CCPA. Fortunately, Vael has created a CCPA Data Broker Email Template. We hope this template can at least save you a little bit of time when submitting your CCPA data requests to People Finders, Spy Dialers, and Traackrs of the world.
When thinking of what requests to submit to data brokers, we highly recommend submitting a request to delete and a request to opt-out (of sale), but this is to your discretion. The request to delete will require data brokers to delete personal information they have about you and the request to opt-out will prevent data brokers from selling your information to third-parties.
Beyond Data Brokers
Looking beyond data brokers, Vael has created the Vael CCPA Detector. The Vael CCPA Detector is a Chrome extension that helps identify what companies (beyond data brokers) are subject to CCPA while you’re browsing the internet, and helps you more easily submit your CCPA data requests to these companies. This is Vael’s first step in making CCPA a little bit easier for Californians.
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