The policy directs California residents to a separate CCPA-specific notice for information about their rights under California privacy law, including rights to access, deletion, correction, and opt-out of data sale or sharing.
This analysis describes what ADP's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision identifies a jurisdiction-specific supplement that governs California residents' data rights, which is operationally significant because CPRA rights including the right to opt out of sale or sharing for targeted advertising apply to ADP's data controller activities and are governed by the California notice rather than the global policy.
Interpretive note: The content of the California CCPA supplement is referenced but not reproduced in the document text provided, so the specific rights, opt-out mechanisms, and data categories disclosed therein cannot be fully assessed from this document alone.
ADP deleted the cookie preference management tool that previously allowed users to understand and control which cookies were placed on their devices, including functional, analytics, and advertising cookies. The removal eliminates the transparency mechanism through which users could consent to or opt out of different cookie categories. The practical effect depends on whether ADP has replaced this functionality elsewhere or whether cookies continue to be placed without equivalent granular user control.
View change record →California residents' privacy rights under CCPA and CPRA, including the right to know what personal data is collected, the right to delete, the right to correct, and the right to opt out of the sale or sharing of personal data, are addressed in a separate California-specific notice referenced by the policy rather than in the global privacy statement itself.
How other platforms handle this
If you are a California resident, you have the right to know what personal information we collect, use, and disclose about you; the right to request deletion of your personal information; the right to opt out of the sale or sharing of your personal information; the right to correct inaccurate person...
If you are a California resident, you have the right to: Know what personal information is being collected about you; Know whether your personal information is sold or disclosed and to whom; Say no to the sale of personal information; Access your personal information; Request deletion of your person...
Depending on where you are located, you may have certain rights regarding your personal information, including the right to access, correct, delete, or restrict processing of your personal information, the right to data portability, and the right to object to or withdraw consent for certain processi...
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"If you are a California resident, please see our California Consumer Privacy Act Notice for additional information about your rights and our privacy practices.— Excerpt from ADP's ADP Privacy Statement
1) REGULATORY LANDSCAPE: This provision engages the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), enforced by the California Privacy Protection Agency (CPPA) and the California Attorney General. The CPRA expands CCPA rights to include correction, sensitive data restrictions, and opt-out of sharing for behavioral advertising in addition to sale. The provision also engages any California-specific requirements for employee and business contact data under CPRA's expanded scope. 2) GOVERNANCE EXPOSURE: Medium. The adequacy of the California supplement, particularly whether it includes a functional opt-out mechanism for data sale and sharing, a description of sensitive personal information collected, and retention periods, is subject to CPPA enforcement. Organizations that share employee data with ADP and California employees interact with ADP platforms should ensure their own CCPA notices reflect ADP's role. 3) JURISDICTION FLAGS: California residents including both ADP direct service users and employees of ADP client organizations (where ADP may act as a service provider under CCPA) are the primary affected population. The CPPA has enforcement authority and has issued regulations under CPRA that specify notice content requirements, opt-out signal recognition, and retention disclosure obligations. 4) CONTRACT AND VENDOR IMPLICATIONS: ADP client organizations with California employees should confirm whether ADP's CCPA classification as a service provider (processor) or third party (controller) for various data categories is consistent with the organizations' own CCPA privacy notices and data processing agreements. If ADP qualifies as a service provider, the service agreement must prohibit ADP from using California employee data for its own commercial purposes. 5) COMPLIANCE CONSIDERATIONS: Legal teams should review the full text of ADP's California CCPA supplement to verify that opt-out mechanisms, sensitive data rights, retention disclosures, and the list of data categories sold or shared are complete and current under CPRA regulations. The California supplement should also address whether ADP honors Global Privacy Control (GPC) signals as required by CPPA regulations.
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This provision identifies a jurisdiction-specific supplement that governs California residents' data rights, which is operationally significant because CPRA rights including the right to opt out of sale or sharing for targeted advertising apply to ADP's data controller activities and are governed by the California notice rather than the global policy.
California residents' privacy rights under CCPA and CPRA, including the right to know what personal data is collected, the right to delete, the right to correct, and the right to opt out of the sale or sharing of personal data, are addressed in a separate California-specific notice referenced by the policy rather than in the global privacy statement itself.
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