California Privacy Agency’s First Enforcement Action Against Honda

On March 12, 2025, the California Privacy Protection Agency (“Agency”) announced a settlement with American Honda Motor Company, marking the Agency’s first enforcement under the California Consumer Privacy Act (“CCPA” or “Act). The settlement required the auto company to change its business practices and pay a $632,500 fine to resolve allegations of CCPA violations.

The Agency alleged that Honda violated California residents’ privacy rights by:

1. Requiring excessive information requests to exercise privacy rights, such as opting out of the sale of data.
2. Using an online privacy management tool that made opting out of data sharing more difficult than opting in.
3. Complicating the process for users to authorize individuals or organizations to exercise their privacy rights on their behalf.
4. Sharing users’ personal information with ad tech companies without having contracts in place that include the necessary privacy protections.

To address the concerns, within 90-180 days, Honda must implement a more straightforward process for users to assert their privacy rights, offer “symmetry in choice” for cookie options, provide an updated training to all employees who handle CCPA requests, consult a user experience designer to evaluate its methods for submitting privacy requests, ensure contracts with all third-party data recipients contain CCPA-compliant terms, and certify its compliance.

In addition to the remedial measures, Honda must pay an administrative fine of $632,500. Of that amount, $382,500 is allocated to 153 consumers whose rights were impacted by the company’s practices. Under the Act, the Agency can impose fines of up to $2,500 per violation— or $7,500 per intentional violation —with adjustments for inflation.

The settlement emphasizes the Agency’s commitment to enforcing the CCPA, with substantial penalties for non-compliance. Organizations must ensure their CCPA compliance program is updated and their privacy policy is thoroughly reviewed.

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