Possibly.

While modern privacy statutes in the United States and Europe adopt a similar definition of “profiling,” the term has yet to be judicially interpreted or applied in the United States. Within Europe, the Article 29 Working Party took the position that for an action to constitute profiling three elements must be met:

  1. An activity

While the CCPA went into effect on Jan. 1, 2020, it did not become fully enforceable until July 1, 2020. When we passed the one-year anniversary of the CCPA becoming law, it provided an opportunity to assess the impact of the CCPA on privacy programs and to begin to benchmark against emerging industry standards. To