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CCPA and LDU: Is your Facebook pixel compliant?

By: Angela Besprozvanny    October 28, 2020

Facebook was a little bit late in addressing the California Consumer Privacy Act (CCPA), which created confusion for many marketers on how to ensure they were covered. In July, Facebook automatically enabled Limited Data Use (LDU) across accounts. This meant that Facebook was automatically viewing all California residents as opting out of data collection. LDU was only enabled through the end of July but could be extended to October 20.  After October 20, advertisers had to implement the LDU flag on a site in order to be compliant. In order to check whether LDU is enabled on your site, you can look for data processing parameters within the Facebook pixel manager.

Do you need to enable LDU? The question to ask yourself is, “Does my business collect any personal data from California residents, even cookie IDs?” If yes, then you should evaluate implementing LDU and consult with your legal team for compliance.

What will this impact?

Depending on how you have set up LDU, the data you have available for retargeting and campaign measurement in California will be most affected. In order to minimize the impact of LDU, it is helpful to enable the flag to fire only when someone has opted out from a consent banner on your site. This way, Facebook will limit the use of data for only people who have opted out. A workaround for site retargeting that marketers are testing is retargeting post engagement from users in California if site data is very limited.

Since CCPA is based on users opting out from data collection, the rate of people opting out should be much lower than a regulation such as General Data Protection Regulation (GDPR), which requires opt-in. If California is a main market in your campaign, then separating it out into its own campaign will help you closely monitor the impact and adjust your strategy.