CCPA @ Looker FAQ
Version January 10, 2020
The Looker Platform can provide benefits with regard to CCPA compliance.
Looker supports CCPA compliance in three ways: Product, Architecture, and Company readiness.
What is the CCPA?
The California Consumer Privacy Act of 2018 (CCPA), effective January 2020, is the privacy law that generally applies to companies anywhere in the U.S. or beyond that have consumers located in California. It is designed to give consumers in California additional rights over the collection and sharing of their personal information.
The CCPA implements several rights that either enhance existing rights of Californians, such as the right to be informed, provides new rights similar to those of Europe's GDPR, such as the right to delete, and adds a new right to opt-out of the "sale" of personal information. The definition of a "sale" under CCPA is broad and may include data sharing that consumers typically would not associate with a "sale". Looker is a Service Provider to its customers and its users; our customers are a covered Business under the CCPA. Looker is not a Third Party to its customers. Looker does not sell personal information, in the provision of our Products and Services.
Product and Services.
The Looker platform works in-database, and therefore does not extract your personal information or customer data from your databases. The Looker platform and services provides features to assist with data management, setup (such as, JumpStart or Connections), and processes to help you meet data security and privacy requirements.
Architecture.
The Looker Product and Services offer a simpler, transparent architecture for data processing which reduces data sprawl and can support compliance with CCPA requirements such as deletion. The Looker platform creates a single, governed location for users to access data. It gives administrators control over who's accessing data and how long it's cached for. The Looker platform leaves control of your data where it belongs, in your hands.
Has Looker evaluated its security policies, management, and controls to meet CCPA?
Our data security program is designed to ensure that the policies, controls and processes are appropriate to the type of personal information and data processing collected, including ISO27001, SOC2 Type 2 which have reasonable practices equivalent to the CIS20. You can find our security standards here: https://looker.com/product/security
What security certifications does Looker have?
We have received certification for SOC 2 Type 2 Report (+HIPAA) and ISO27001 for the Looker AWS Cloud Hosted Data Platform, and SOC2 Type 1 Report. For the Looker GCP Cloud Hosting Data Platform. https://looker.com/product/security
For additional details on Looker security policies, management, and controls, please work with your AE to obtain access to our security portal.
You will need to sign an NDA before receiving access to Looker compliance documents.
Information for Customers
My company is considering Looker or is an existing customer - do you have a Customer CCPA addendum? What is the CCPA Addendum for Customers and how does it work?
Looker Customers will need to determine if they are subject to the CCPA. If you believe that your company is subject to CCPA, please sign and return Looker's CCPA Addendum for Customers to your AE. This Addendum is intended to modify the current agreement, including data protection agreement between your company and Looker. It includes necessary terms and commitments between Looker and your company, and that Looker is in the role of a Service Provider under CCPA, which means that we are performing services for your company and not independently using personal information that we process on our your behalf for our own commercial purposes. It also clarifies that there is no exchange of personal information for consideration or "sale" of personal information between our customers and Looker.
Looker is a Service Provider to customers. How does Looker respond to CCPA rights requests from Customers? Users?
As a Service Provider to Looker's customers, Looker does not make decisions about the validity of CCPA rights requests - that is a decision the customer must make. A customer's user does not have a consumer relationship to Looker and therefore In the event that Looker receives requests from users of the Looker platform, Looker will refer those requests to the customer for management and response. For user deletion requests, we provide that capability to admins. Customers should be careful about whether to fully delete a user - which would also delete queries, dashboards, etc that user created. There is a partial deletion that retains the links to queries and dashboards: https://docs.looker.com/admin-options/tutorials/delete-user
What personal information does Looker as a Service Provider, collect and store, and for what purposes?
Looker, as a Service Provider, holds two classes of data: personal information about Looker Users and the customer data (in database) necessary to answer Users' queries.
Information about Looker Users includes end-user login/registration account information for Looker Users plus metadata about their usage of Looker Products and Services.
- Metadata is used to facilitate product improvements, customer support and license auditing.
- Login information is controlled by customers directly as it is entered on their Looker instance and they can delete their Looker Users' (i.e. their employees') information at any time.
- We retain basic user account information, which includes User contact information used to send product updates, relevant marketing, training and events based on the Users' contact preferences.
Customer data necessary to answer Users' queries is data retained in the Looker cache, fetched in response to Looker User queries of their databases connected to Looker.
- This data is encrypted and stored by Looker for a maximum of 30 days or 2GB of data—whichever occurs first. Customers may take additional steps to reduce the amount of time that query results are held in cache.
For more information on how we collect and use personal data, our privacy policy is here:
https://looker.com/trust-center/privacy/ca-privacy-notice
How long does Looker retain customer data? Will Looker delete customer data when requested?
As a customer of Looker, you remain in control of your data in your databases and personal information about your Looker Users. Looker does not extract or store the customer data in your data stores. When you remove Looker Users from your Looker instance, their data will be removed from Looker's cache within 30 days. If you wish to delete a Looker User's account data, our Data Engineering team has a process to permanently anonymize the data. If you would like Looker to delete your customer data in cache or Looker User account personal information, please send an email to privacy@looker.com.
How is personal or sensitive information stored?
This relates to how the Looker product works in a hosted environment. Personal information and sensitive information remains in your database because Looker works within your database -- Looker does not extract information from customer data sources. We strongly encourage customers to not include sensitive or personal information in email, chat, or other messaging service.
Is there a way the customer can configure how long logs are stored for a customer instance?
The cache and log criteria can be reconfigured by the Looker admin - all covered in product security documentation.
Where does Looker host customer data?
Looker-hosted instances are hosted in the Amazon Web Services (AWS) or Google Cloud Platform (GCP). By default, Looker hosts in the AWS U.S. (Virginia) region, but at the customer's request, we can host in various other regions. Customers who desire hosting in other locations: we offer AWS's Ireland, Germany, Japan, Australia and Brazil. GCP offers hosting in several locations around the world. Customers can also host their own Looker instance on their servers.
Information for Vendors
Looker requires our Vendors that process customer data to act as a Service Provider. What is the CCPA Addendum for Vendors and how does it work?
Vendors to Looker that process customer data are Service Providers -- not a Third Party -- under the CCPA. Looker's Vendor CCPA Addendum is here. This Addendum modifies the current agreement and includes commitments that these vendors will comply with the CCPA in the role of a Service Provider, which means that they are performing services for Looker and not independently using personal information from Looker for their own commercial purposes. It also clarifies that there is no exchange of personal information for consideration or "sale" of personal information between the vendor and Looker.
The Vendor CCPA Addendum relies on the preexisting data protection terms between the vendor and Looker, which are typically found in the Data Protection Agreement (DPA) to ensure that reasonable security methods in place. Vendors interested in updating their current DPA should send a request to dpaprocessing@looker.com.
Information for Consumers
Am I a "consumer" to Looker under the CCPA?
Consumers act on their own behalf in the relationship to Looker. Examples of when you are a "consumer" to Looker under the CCPA include if you are a Certification Examinee, a Community member or a visitor to our website.
Where can I find information about my CCPA Rights for Consumers in California?
Refer to our California Privacy notice for details about your rights and other useful information: https://looker.com/trust-center/privacy/ca-privacy-notice
May I opt out of Looker Communications?
Yes. We retain basic Looker User contact information to communicate with our prospects, customers, and their users about product and security updates, relevant marketing, training and events. Looker Users may manage their communication preferences at our subscription center here.