CPPA Enforcement Against Honda: Key Lessons for CCPA Privacy Law Compliance
The California Privacy Protection Agency (CPPA) recently imposed a $632,500 fine against American Honda Motor Co. for violations of the California Consumer Privacy Act (CCPA). This enforcement action—one of the first significant penalties by the CPPA—provides critical insights into the agency’s priorities and expectations for businesses handling consumer data.
Core Violations Highlighted in the Case
1. Overcollection of Data for Privacy Requests
Honda required consumers to submit nine pieces of personal information (e.g., name, email, VIN) to verify opt-out or sensitive data limitation requests. Regulators clarified that certain non-verifiable privacy rights requests (like opt-outs of sale/share) do not require such verification (whereas others do, such as requests to delete and access).
2. Imbalanced Consent Interfaces
Honda’s cookie banner design required users to take two steps to opt out of data sharing (toggling off cookies + confirmation) but only one click to opt in. This asymmetry was deemed non-compliant, as it discouraged privacy-protective choices and is deemed a “dark pattern” tactic.
3. Obstacles for Authorized Agents
The company required consumers to verify requests submitted via authorized agents for Opt-Out of Sale/Sharing and Requests to Limit where such requests are not subject to such verification.
4. Lacking Third-Party Data Processing Agreements
Honda failed to include required data use restrictions in contracts with advertising partners, leaving consumer data inadequately protected.
The CPPA stated:
Those agreements must contain explicit provisions that protect Consumers. For example, the agreements must identify the limited and specified purposes for which the Personal Information can be used and must limit the recipient’s use of the Personal Information for only those purposes. The agreements must also require the recipient to comply with the CCPA and provide the same level of privacy protection as required of businesses by the CCPA, among other things… Despite Collecting, Selling, Sharing, and disclosing Personal Information with these advertising technology companies, Honda could not produce contracts with these advertising technology companies.
Actionable Compliance Strategies
Simplify Verification Processes
- Use minimal required data for identity verification.
- Eliminate verification entirely for low-risk rights like opt-outs.
Design Neutral User Interfaces
- Ensure “Accept All” and “Reject All” buttons require equal effort.
- Avoid dark patterns like pre-toggled consent or layered menus.
Streamline Authorized Agent Access
- Accept agent-submitted requests and only require verification where required.
- Publish clear submission guidelines in privacy policies.
Strengthen Vendor Management
- Audit contracts and ensure for robust data processing agreements (DPAs) to ensure mandatory data protection clauses.
- Implement centralized tracking for third-party agreements.
Conduct Proactive UX Testing
- Involve legal teams in reviewing cookie banners, targeted advertising, preference centers, and request workflows.
- Test interfaces across geographies to ensure accessibility.
Industry Implications
This case signals the CPPA’s focus on technical compliance—not just written policies. Automotive companies and IoT device manufacturers should expect heightened scrutiny, particularly regarding:
- Connected vehicle data practices
- Cookie banner symmetry
- Frictionless opt-out mechanisms
Organizations must treat privacy interfaces as mission-critical systems, subject to regular audits and user testing. With the CPPA now fully operational, similar enforcement actions are likely to accelerate across sectors.
