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Video Conferencing and the CCPA

By Shaia Araghi and Kyle Janecek
November 01, 2020

The use of videoconferencing platforms has spiked significantly due to COVID-19 closures. With this spike, some users have become increasingly concerned about the privacy of these platforms, due to exposure of information from security breaches. We examined the privacy policies of six prominent videoconferencing applications to determine their compliance with the California Consumer Privacy Act (CCPA). This should serve as a reminder to all organizations about the importance of following CCPA guidelines.

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Evaluation Process

To evaluate these videoconferencing platforms' compliance with the California Consumer Privacy Act, we examined the finalized CCPA regulations under Title 11, Division 1, Chapter 20, specifically sections 999.308, 999.317 (g)(1), and 999.332. These regulations were approved by the Office of Administrative Law on Aug. 14, 2020. These regulations generally require a disclosure of rights, instructions on how to enforce rights, and transparency regarding the collection, disclosure, and sale of information. We reduced the requirements into a chart and reviewed the privacy policies (as of Aug. 26, 2020) for each platform.

CCPA Regulations Zoom Webex Go To Meeting (LogmeIn) Skype (Microsoft) Teams (Microsoft) Wire
Dated Privacy Policy Yes Cisco Privacy Policy: Yes Data Sheet: No Yes Yes Yes Yes
Explanation about a right to know the personal information it collects, uses, discloses, and sells and right to delete Yes, under Data Subject Rights Yes, but part of different documents Yes Yes Yes Yes
Provides agent instructions No No No No No No
Instructions for requests to know information/deletion Yes, but deletions are restricted to profile information. Yes, though verification is not given Yes, though verification is not given Yes, Yes Yes, though verification is not given and deletions are restricted to profile information.
Identifies the categories of personal information Collected. Yes, but not as laid out in statute Yes, but not as laid out in statute Yes, but not as laid out in statute Yes Yes Yes
Identifies where personal information is obtained. Yes Unclear Yes, but slightly unclear. Yes Yes Yes, but minimal details were provided.
Explain that the consumer has a right to opt-out of the sale of their personal information by a business. Yes N/A; No sale occurs Yes N/A; No sale occurs N/A; No sale occurs N/A; No sale occurs
State whether or not the business sells personal information. No Sales No Sales  (without consent) No Sales No Sales No Sales No Sales
Identifies the business or commercial purpose for collecting personal information. Yes Yes Yes Yes Yes Yes
Identifies the categories of personal information, disclosed to third parties No, but instances listed Yes No, unclear Yes Yes Yes.
Listing the categories of third parties to whom the information was disclosed or sold. No Yes Claims it is exempt under the "Shine the Light" law No No No
Provide contact information for privacy issues Yes Yes Yes Yes Yes Yes
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Findings

We determined that none of the major videoconferencing platforms were fully compliant with the CCPA. Certain requirements (such as providing instructions to consumers about the process of exercising their rights or how authorized agents are appointed) were not adequately addressed. Furthermore, WebEx (Cisco), Skype, and Teams (Microsoft) featured some non-user-friendly elements: These platforms did not have a unified privacy policy for consumer review. However, Microsoft's platforms explicitly referred to two-factor authentication measures to help verify and secure information. WebEx provided categories of third parties they share information with. All platforms made a necessary disclosures of rights, while Zoom and Go to Meeting provided the most details regarding consumers' rights.

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