Don’t Be The Next Target of the CPPA
March 24, 2025
On March 12, 2025, the California Privacy Protection Agency (CPPA) announced that it reached a settlement with the Honda Motor Company for violations of the California Consumer Privacy Act after an almost two-year investigation.
The investigation revealed that Honda committed four primary violations. Understanding the nature of these investigations helps dealerships to look for similar potential violations in their privacy notice and customer rights compliance architecture.
Violation number one identified that Honda required consumers to provide excessive personal information when exercising their privacy rights. The California Consumer Privacy Act (CCPA) mandates that customers must be able to opt out of the sale or sharing of personal information without undergoing a verification process. Honda made this process too difficult in the eyes of the CPPA investigators.
In the second violation, the CPPA found that Honda’s on-line privacy rights platform made it easier for consumers to opt in than it did to opt out which violates section 7004(a) of the CCPA.
The third violation found that Honda made it difficult for authorized third parties to exercise privacy rights on behalf of their customers.
The last primary violation found that Honda failed to produce contracts with its ad tech providers that included the required privacy safeguards.
How does this help a dealership make sure its privacy rights compliance passes regulator scrutiny? The CPPA action gives a short checklist of what dealership managers and principals should address in their privacy statements and policies.
- Are your privacy policies clear and concise and do they accurately reflect the legal requirements granted to the consumer by their state; does your privacy compliance tool determine the geographic location of your customer?
- Are the opt in and opt out processes fair and equitable, meaning the opt out is as easy as the opt in feature?
- Do you require the customer to provide excessive personal information to exercise their privacy rights?
- Do you know where customer information is shared when they provide it to you and do the vendors with whom this data is shared have the ability to comply with opt in/out and other requests required by various state laws?
With more and more states following the example set by California with consumer privacy rights, the day of dumb, static cookie banners has passed. Your banners must be tuned to the laws of the state in which a consumer resides. They must be agile enough to manage complex requests. Your dealership needs operational policies to execute consumer requests and provide the required customer notifications.
With fines that can quickly add-up, California allows for $2,500 per occurrence and up to $7,500 per occurrence for intentional violations, ignoring your privacy rights program can prove costly! The action taken against Honda shows that states are serious about enforcing customer privacy rights. California has taken the lead, and you should expect others to follow.
If you want to explore solutions to address your privacy rights compliance needs, contact Accelerate2Compliance at (844) 637-5511 or email [email protected].
Matt Vatter
Chief Compliance Officer, Accelerate2Compliance
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