The Case Overview

On February 21, 2024, DoorDash agreed to a $375,000 settlement, exposing critical vulnerabilities in how businesses handle and share consumer personal information.

Key Violations

DoorDash was found to have:

  • Sold customer personal information without proper notice
  • Failed to provide opt-out opportunities
  • Participated in marketing cooperatives that improperly shared data
  • Disclosed customer data to non-cooperative businesses
  • Allowed data broker to resell customer information multiple times

Official Case Documents

  • Total Settlement: $375,000
  • Violations of California Consumer Privacy Act (CCPA)
  • Violations of California Online Privacy Protection Act (CalOPPA)
  • Significant penalties for unauthorized data sharing

Key Compliance Requirements

DoorDash was required to:

  • Review contracts with marketing and analytics vendors
  • Implement technology to evaluate data selling/sharing
  • Provide annual reports monitoring potential data sales
  • Develop more transparent data sharing practices

Broader Context

The case highlighted:

  • Risks of participating in marketing cooperatives
  • Complexities of data sharing in digital platforms
  • Importance of clear consumer data notifications
  • Challenges of controlling data beyond initial collection

Key Takeaways

  • Marketing data sharing requires explicit consent
  • Businesses must carefully manage vendor relationships
  • Transparency is critical in data ecosystem
  • Third-party data brokers pose significant risks