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The term “personally identified information” is utilized by some industry groups, including the Network Advertising Initiative (“NAI”).  Personally identified information, or “PII,” is defined by such organizations to refer to a significantly narrower set of data than the term “personal information” used within the CCPA.  The following provides a side-by-side comparison of the two terms:

CCPA

Section 1798.140(0)(1)

NAI

2020 Code of Conduct

“Personal information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information includes, but is not limited to, the following if it identifies, relates to, describes, is capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household . . .

“Personally-Identified Information (“PII”) is any data linked, or intended tobe linked, to an identified individual, including name, address, telephone number, email address, financial account number, and non-publicly available government-issued identifier.

 

One of the most important differences between the two definitions is that “personal information” for purposes of the CCPA includes information that “could reasonably” be linked with a particular consumer,” whereas “personally-identified information” for purposes of the NAI only refers to data that is actually linked or subjectively intended to be linked to an identified person.