Compliance for the collection, usage, processing and transfer of personal data in relation to marketing research
The California Consumer Privacy Act (“CCPA” or the “Act”) went into effect January 1, 2020. This sweeping legislation creates significant new requirements for identifying, managing, securing, tracking, producing and deleting consumer privacy information.
The CCPA takes the position that consumers “own” their privacy information and provides them five general “rights” for their personal information. Under the Act, California consumers will have the right to request information regarding:
- The categories of personal information businesses collect about them (e.g., identifiers such as their names, Social Security numbers, IP addresses, email addresses, postal addresses; purchasing histories; geolocation data, biometric information, internet activity such as web browsing histories; and professional or employment-related information)
- The sources from which that personal information was collected (e.g., online order histories, online surveys, marketing companies, tracking pixels, cookies, web beacons, or recruiters)
- The categories of personal information “sold” to third parties**
- The categories of personal information disclosed for business purposes
- The categories of third parties to whom personal information was sold or disclosed (e.g., tailored advertising partners, affiliates, social media websites, service providers)
- The business or commercial purposes for which personal information was collected or sold (e.g., fraud prevention, marketing, improving customer experience)
- The “specific pieces” of personal information collected
As a company who provides services which include interactions with consumers or customers, we understand the requirements of CCPA and how to handle any consumer requests related to CCPA and personal information (PI).
CCPA broadly defines the term PI (or PII) as “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” CCPA’s expansive definition of the term PI includes data such as internet protocol (IP) addresses; search and browsing history; call history; as well as inferences drawn from these data elements that could create a profile about a consumer.
More specifically, “Personal information” means:
An individual’s first name or first initial and his or her last name in combination with any one or more of the following data elements, when either the name or the data elements are not encrypted or redacted:
- Social security number
- Driver’s license number or California identification card number
- Account number, credit or debit card number, in combination with any required security code, access code, or password that would permit access to an individual’s financial account
- Medical information
- Health insurance information
Ensuring Data Privacy and Compliance
We have taken the following measures to ensure data privacy and compliance with the California Consumer Privacy Act (CCPA) as well as other privacy regulations, such as GDPR.
- We have conducted a data protection impact analysis (DPIA)
- We have reviewed and continue to review the data we hold and our data collection processes
- We have updated our privacy policies
- We have added opt out links onto the footer of our websites and included a toll-free number for telephone opt out requests
- We have appointed a Data Protection Officer
- We have addressed our ability to provide personal data information upon request, the right to be forgotten (deletion), and data portability
- We have addressed data protection by design and default
- We have addressed secure data transfer
- We have addressed the issue of risk
- We have prepared a data breach notification process
- Robust data protection technology is in place and regularly assessed and updated
Data Protection Officers
Insight Safari LLC
T. 866-587-1546 x 105
Contact Information (Insight Safari LLC)
Insight Safari consumers can request access to or deletion of their PI, and to otherwise exercise their CCPA rights, regardless of whether they are a California resident or not. Anyone who would like to request access to or deletion of their data, or otherwise indicate they are exercising any of their CCPA rights, can contact us by email or phone.
Mail: Insight Safari LLC, Privacy Inquiries
365 Riverbluff Pl
Memphis, TN 38103