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Colorado Publishes Universal Opt-Out Mechanism Shortlist

13 Dec

Update Applicable to:  Effective date
All employers that keep records of customers in the state of ColoradoThe Colorado Privacy Act Rules were effective on July 1, 2023.   Universal Opt-out Mechanisms will be effective on July 1, 2024.   Comments and feedback on the Colorado DOL UOOM shortlist must be done before or on December 11, 2023.

What happened?

On November 11, 2023, the Colorado Department of Law (DOL) released a preliminary list of potential universal opt-out mechanisms (UOOMs). These mechanisms are intended to enable consumers to opt out of the sale of their personal data or its use in targeted advertising. Companies will be mandated to comply with any UOOMs that are finalized and included in the ultimate list.

What are the details?

After the Colorado Privacy Act Rules were put into effect, the Colorado Attorney General released a compilation of potential Universal Opt-out Mechanisms (UOOMs). This list is designed to assist Controllers, Consumers, and other stakeholders in meeting their obligations under the Act.

To help consumers and controllers understand which UOOMs meet such standards, the Colorado Privacy Act (CPA) requires the AG to publish and maintain a public list of UOOMs that controllers must process (Section 4 CCR 904-3-5.07). The AG will consider the public’s feedback when selecting the UOOMs that the final list will include.

The shortlist only includes three UOOMs:  Opt-Out Code, the Global Privacy Control (“GPC”), and Opt-Out Machine.

While the Colorado Privacy Act mandates a universal opt-out system for consumers from all sales and targeted advertisements, the required technology is not entirely in place. This is because targeted advertising cookies typically do not link with the personally identifying information that’s commonly used in traditional data sales. By choosing a list that covers three distinct situations, the Department of Law (DOL) is establishing a framework that permits consumers to opt out universally, even if it means employing three separate Universal Opt-out Mechanisms (UOOMs) instead of just one.

The AG is expected to publish the final list of qualifying UOOMs by January 1, 2024.

Best practices

Employers should review additional resources here:

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