This allows them to promise that they don't keep any data and have strict retention policies etc. to jurisdictions that are on the fence or where the contract-purchasers are constrained by law in some way, but they can transfer identifying information at any point in the future to any customer, by mixing raw data and a model.
How could this seriously hold legal weight? The data is identifiable. Just because it’s gated by some transformation doesn’t mean they are magically not holding my identifiable information.
1798.140 (v)
> “Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information includes, but is not limited to, the following if it identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household."
The phrase "reasonably capable of being associated with" seems like it would apply against this transformation argument, but later:
> (2) (A) “Personal information” does not include publicly available information or lawfully obtained, truthful information that is a matter of public concern.
> (B) (i) For purposes of this paragraph, “publicly available” means any of the following:
> (II) Information that a business has a reasonable basis to believe is lawfully made available to the general public by the consumer or from widely distributed media.
So I think the above comment was wrong, this might be the actual way around it, AIUI courts have long established that individuals don't have a reasonable expectation of privacy from being photographed or recorded when in public, so it seems like public surveillance footage is actually exempt from CCPA even if it can be reasonably linked with personally identifying information.