Before we are able to provide you with or delete any data, we are legally obligated to receive a “verifiable consumer request.” Companies are PROHIBITED by the California Consumer Privacy Act from sharing personal information with consumers without “a reasonably high degree of certainty” that the person making the request is the consumer in question.
Weeklys expects to be legally unable to verify the identity of many consumers who ask us to provide or delete their data. Unless you have done business with our company or have an account with one or more of our publications, it is unlikely that we possess enough information about you to legally verify your identity. The reason for this is that Weeklys stores information in a variety of separate, disconnected databases. If you subscribe to an email newsletter we have your email address in one location, but probably not your name or street address. If you have commented on our website, a separate database may know you only by your online alias or username. If you have visited our website, we may have saved your IP Address in a third database, but probably not your name or your email address. In most cases, we never connect the data in these separate repositories — and have no way of doing so even if we wanted to.
The California Consumer Privacy Act defines a verifiable consumer request as one “made by a consumer, by a consumer on behalf of the consumer’s minor child, or by a natural person or a person registered with the Secretary of State, authorized by the consumer to act on the consumer’s behalf, and that the business can reasonably verify … to be the consumer about whom the business has collected personal information. A business is not obligated to provide information to the consumer … if the business cannot verify … that the consumer making the request is the consumer about whom the business has collected information or is a person authorized by the consumer to act on such consumer’s behalf.”
For the purposes of complying with requests to inspect the SPECIFIC PERSONAL INFORMATION that we have collected about you, the California Attorney General’s Office has proposed regulations that require businesses to match AT LEAST THREE DATA POINTS provided by you with data already in our possession, to “a reasonably high degree of certainty.”
For the purposes of complying with requests to learn the CATEGORIES OF PERSONAL INFO that we may have collected about you, the California Attorney General’s Office has proposed regulations that require businesses to match AT LEAST TWO DATA POINTS provided by you with data in our possession, to “a reasonable degree of certainty.”
For the purposes of complying with requests to delete the specific personal information that we may have collected, the California Attorney General’s Office has proposed regulations that require businesses to verify the identity of the consumer to a “reasonable or reasonably high degree of certainty depending on the sensitivity of the personal information and the risk of harm posed to the consumer by unauthorized deletion.” Thus, we will require you to provide AT LEAST TWO OR THREE DATA POINTS that we already have in our possession.
Although each attempt to verify a consumer’s identity will be based on unique information, here are some examples of the types of information that might enable us to verify a consumer’s identity: A unique username, personal password, email address or phone number that you can retrieve messages from, last four digits of a credit or debit card, record of a persona business transaction with our company, or other unique personal information that only you might possess.
Weeklys also is required to respond to information requests on your behalf from any authorized agent that you select to handle such requests for you. We will require that agent to provide legal proof that they have been authorized by you. Such requests will then also require sufficient data from your agent to verify that you are the person in our records.
It is entirely up to you what type of information you provide us for verifying your identity. However, the California Attorney General’s office and Weeklys discourage you from supplying the following information for this purpose: Social Security numbers, driver’s license numbers, California ID card numbers, tax ID numbers, passport numbers, military ID numbers, or other government-issued ID numbers; credit or debit card numbers, security or access codes, or passwords that would enable anyone to access your financial account(s); medical or health insurance information; unique personal biometric data; usernames or email addresses in combination with passwords or security questions that would enable anyone to access an online account.
We nonetheless are limited in our ability to conduct a thorough search for your personal information by the amount of information that you do provide us with. For instance, if you verifiably ask us to search for information on John Doe who lives at 1234 S. Main St., we will provide you with all the information associated with that name and address, but that won’t include any information that we only associate with
JDoe87@email.com.
Finally, for the purposes of proving that it has complied with the law, Weeklys and other companies are LEGALLY REQUIRED by the California Consumer Privacy Act to maintain a record of all these requests. So please understand, as strange as it may seem, that we will keep whatever information you submit to us as part of your effort to safeguard your personal data. Information maintained for record-keeping purposes shall not be used for any other purposes.