Aspen Policy Academy

• Aloni Cohen

The California Consumer Privacy Act (CCPA) will go into effect in 2020. It governs the ways companies can use the personal information of consumers. Understanding the meaning of probabilistic identifiers (PI), a type of personal information, is critical to understanding the scope of CCPA, but unfortunately, the legislative language for this term is vague and inconsistent.

The California Attorney General (AG) has the ability to clarify this meaning through regulation. To ensure the closing of potential loopholes and to regulate cross-device tracking, this project recommends the AG clarify that probabilistic identifiers can take many forms, including data that is not “personal information,” and acknowledge that it is the power of the data, not simply its form, that matters for consumer privacy.

Click right to download the policy brief and to read the Protego Press article.