CCPA Opt-Out Guide for Developers

Understanding Opt-Out

Under CCPA, Sale is broadly defined as The disclosure of personal information to a third party for a monetary valuable consideration. Because of this, many organizations consider third-party web trackers (AdTech) in scope of for opt-out.

This document is intended as a guide for developers who are deploying OneTrust's solution for CCPA Opt-Out of Sale on their web sites.

Considerations

Before deploying this solution, you should consider the following:

  • What technology is already deployed on your site? There are many different tracking technologies (cookies, tags, beacons, etc.) that could potentially fall within the scope of sale. Knowing and understanding what these are will determine the priorities of what needs to be blocked and how to block them.

  • What obligations do you have, in terms of disclosure? Is your organization going to leverage a disclosure (cookie) banner, or will the opt-out mechanism be placed behind a button?

  • Determine the user experience during the opt-out. The options are:

    1. One-click Link

    2. Preference Center

    3. Widget

Analysis and Configuration

Regardless of how you choose to implement CCPA Opt-Out of Sale, you will need to analyze your site and configure rules and settings to determine the behavior of the solution for site visitors from different locations.

Analyzing Your Website

The first step to deploying an opt out solution is understanding what trackers are on your site and potentially selling data. The OneTrust site scanner can be used to gather information on third party cookies, tags and associated vendors.

  1. Scan your website. For more information, see Scanning a Website.

  2. Categorize the cookies. For more information see Managing and Categorizing Cookies and SDKs.

    Determine how many groups into which you will categorize your cookies. OneTrust comes seeded with groups for Performance, Functional, Targeting, Social Media, and the Opt-Out of Sale Solution. You have the choice to categorize your cookies into multiple groups or just one.



Configuring Geolocation Rules

After you scan your website and categorize the cookies found, you will need to configure Geolocation rules and design the Opt-Out of Sale Solution.

Geolocation

For instructions on configuring Geolocation Rules see: Configuring Geolocation Rules.

  • If you do not want to show a banner on your site, clear the Show Banner check box.



  • Many organizations have created rules which contain the opt-out behavior and options to a specific region. There are three common approaches:

    • Using a global policy for any visitor that may come to your site. If this is the case, set your “Global” rule to “Opt-Out” and save.

    • Using country-specific geotargeting. To set this opt-out to be US specific, select United States in the Regions field, and save.

    • Using state-specific geotargeting. To do this, select California and save.



Opt-Out Settings

Once you have determined how to leverage geolocation, you can configure the opt-out settings using the consent model for the rule.

There are two common approaches to this:

Opt-Out

Blanket/Full Opt-Out: Selectas the consent model.

Custom

Custom Opt-Out: Selectas the consent model. Then, select the consent approach for each category, setting opt-out for the ones where opt-out of sale is applicable.

Templates

Once you've set up your geolocation rules, you will need to decide on how the site visitor will interact with the opt-out settings. There are several options described below.

For more information, see: Customizing the Banner Template.

Template Options



To create the One Click Opt-Out link:

  1. Create a new template using the CCPA base template.

  2. Create a Geolocation Rule

    Do Not Show

    Selectbanner.

    Opt-Out

    Select.

  3. Generate script

  4. Deploy script for One Click Opt-Out Link. In order for cookie blocking to work correctly, please see Do Not Sell for AdTech Vendors.

Option 2: Preference Center

There are two approaches for setting up a Preference Center. First, opting-out of all third-party ads and subgroups. Second, creating a custom CCPA template that only contains the Opt-Out of Sale group.

For detailed instructions on setting up a Preference Center consult: Customizing the Preference Center Template.

The following is an example of this preference center:



  1. Create a new template using the CCPA base template.

  2. Create a Geolocation Rule

    Do Not Show

    Selectbanner.

    Opt-Out

    Select.

  3. Generate script

Option 3: Widget Layout (Combined Web Form and AdTech Opt-Out)

Add a category for Opt-out of web form. To do this, go to the Categorizations screen and the Categories tab. Then, click Add New and create a category with the name you want to use. For more information, see Managing and Categorizing Cookies and SDKs.

In order to have this category appear, you will need to add a dummy cookie to the group. This cookie will not be displayed. On the Categorizations screen, go to the Cookies tab. Click Add Cookie. Complete the fields and assign it to the site where you would like to use the widget as well as to the group for web form opt-out.



  1. Create a new template using the CCPA base template.

  2. Create a Geolocation Rule

    1. Select Do Not Show banner.

    2. Select Opt-Out.

  3. Generate script

Blocking Mechanisms

In order to actually block the sale of data, you must configure the technologies on your site to adhere to the opt-out of sale request submitted through the link, preference center, or button.

Explanation of Service Provider Addendum

When opting out of the sale, you really only need to block the technology that is transferring PI as part of a "Sale" under CCPA. This may not include all third-party trackers. There are several exemptions to the "Sale" of data. One of the broadest in scope is "sharing information for a business purpose". It applies wherever information is used or shared with a service provider for a "business purpose", which is defined as "a business’s or a service provider’s operational purposes, or other notified purposes".  

Several requirements need to be met for this exception to apply:

  • the transfer must be necessary to perform a task that has a “business purpose”;

  • the transfer must take place “pursuant to a written contract” that prohibits the service provider from “selling, retaining, using, or disclosing the personal information”;

  • the business has provided compliant notice to consumers of the fact that it intends to share with service providers; and

  • the service provider does not further “collect, sell, or use” the personal information of the consumer except as necessary to perform the “business purpose.”

What this means for developers

If your legal team has identified and put in place (contractually) service provider agreements with vendors of the tracking technology on your site, then these may not need to be blocked. Discussing this with your team, and identifying where you may be leveraging service providers are good first steps.

Local Tag and Direct Tracker Blocking

The easiest ways to configure the technologies on your site are to use a tag manager or client-side code to manage your site.

For more information, see: Cookie Consent Integration with Google Tag Manager and Client-Side Cookie Management.

Web Form Configuration

You will need to configure a web form that services the requirements of CCPA's Opt-Out of Sale right for California consumers.

Subject Types & Request Types

Consider which California consumers your organization interacts with and how their data is collected and processed. This evaluation will help determine the appropriate Subject Types that should be listed on your web form.



Request Type customization can vary. A single-select Do Not Sell My Personal Information field is acceptable for some organizations, while some may choose to offer an opt-down method by giving the consumer the choice to opt out of specific (or all) services offered.



The opt-down method requires you to enable the Hide from Web Form setting to omit the Request Type field from the web form, which needs a default value to automatically populate in the form. A second form field must also be added with value options that correspond with the services from which the consumer will choose to opt-out of sale.

For more information, see Creating a Web Form and Customizing a Web Form.





Identifiable Fields

The remaining form fields should be configured with respect to the types of personally identifiable information (PII) required by your organization for record processing. Determine which contacts methods will be used to initiate and track consumer requests or if a specific user or account ID is required to align with the subject and request type.

For more information, see Customizing a Web Form.



Publishing the Web Form

Once your CCPA web form is successfully configured, you can provide consumers access to the form on your website. Save and publish the web form, then determine if it should be placed behind a URL link, a button selection, or in an iframe.

For more information on deploying web forms on your site, see Adding your Web Form to an Existing Website.





Landing Page

Many organizations are fulfilling CCPA opt-out requirements by redirecting users to a Privacy Choice landing page from their Do Not Sell My Personal Information link. This page can provide the consumer choices around how their data is being used. Specifically, for opt-out of sale, this can allow them to opt-out of targeted advertisements through a OneTrust Cookie Preference Center and opt-out of broader use cases through a OneTrust DSAR Form. However, these choices can be broadened to include opting out of the DAA CCPA Framework, submitting a request for access or deletion, or updating communication preferences.

Organizations can opt to have their own web site development teams build these pages, though, OneTrust also provides a template for getting started. For more information, see: Privacy Portal Template.

Regardless if you choose to leverage the OneTrust landing page or your own template, your organization must incorporate the following components, at minimum:

  • OneTrust Cookie Scripts, including Main Script Tag and Do Not Sell/Opt-Out Button Script

  • Opt-Out of Sale web form link

Further aspects for a consumer's privacy choices may also be necessary:

  • Link to DAA CCPA Framework

  • Link to a Consumer Rights Web form

  • Link to an account preference center

Opt-Out of AdTech

You will need to configure your UX as needed for opting out of web trackers. For more information, see: Template Options.

Once your UX is configured appropriately in OneTrust, you will need to configure the landing page itself. A OneTrust template is available for download if your team does not wish to build the entire page independently. Within this template locate the place holders for two OneTrust scripts: the Main Script Tag and the Opt-Out of Sale button.

Note:

You will notice that the HTML template also has place holders to deploy further solutions, which include the DAA CCPA Tooling, a OneTrust Access or Deletion request form, and a link to broader preference management tools.

  1. In the OneTrust application, publish the script for the domain on the page where it will be located. Copy and paste the Main Script Tag into the HTML template.



  2. Place the Main Script Tag into the HTML template.



  3. The opt-out button should be configured prior to open the preference center when clicked.



Opt-Out for Broader Use Cases

The following instructions outline how to create a OneTrust DSAR web form and deploy it on the same central Privacy Choice page. This is intended to allow the consumer to opt-out of any selling of their data that may not originate from AdTech.

First, you will need to configure and publish a web form. For more information, see: Web Form Configuration.

  1. Generate the web form link.



  2. Copy the generated link and paste it into your Privacy Page HTML template.