Continued confusion about how to treat IP addresses under the CCPA
CCPA and IP Addresses – The California State Attorney General submitted the final proposed regulations under the CCPA Regulations on June 2, accompanied by a Statement of Reasons over 500 pages long. Some of you will remember that in the first modification to the Proposed Regs, there was an example included in the definition of personal information. It clarified that an IP address would not be considered personal information if it could not reasonably be linked to an individual. Then, in the second modification, that clarifying language was removed, leading to a ton of confusion. OK… here is the clarification…enjoy!
“To the extent that the comment asks whether the IP address it collects is “personal information,” and thus subject to the CCPA, that is fact-specific and contextual determination. The commenter should consult with an attorney who is aware of all pertinent information, facts, and relevant compliance concerns.”
-Appendix A, Comment 401
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