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Workplace Privacy, Data Management & Security Report

CCPA Compliance Alert: $1.55M Healthline Settlement

By Joseph J. Lazzarotti on August 6, 2025
Posted in California Consumer Privacy Act

On July 1, 2025, California Attorney General Rob Bonta announced the largest CCPA settlement to date, which included a $1.55 million penalty against Healthline Media LLC. This settlement sends a clear message to businesses that California Consumer Privacy Act (CCPA) enforcement is ramping up, and health-related data is in scope.

According to the complaint filed against Healthline, a popular health information website, the state alleged Healthline:

  • Shared sensitive health-related data with third parties without adequate user consent.
  • Failed to provide a clear opt-out mechanism for targeted advertising.
  • Lacked CCPA-compliant contracts with third parties, and assumed, but did not verify, that the third parties had agreed to abide by an industry contractual framework.
  • Transmitted article titles (e.g., “You’ve Been Newly Diagnosed with MS”) that could reveal a user’s medical condition, effectively disclosing personal health information.

This case marks the first time the California Department of Justice has enforced the CCPA’s protections around sensitive personal information.

Operating one of the top 40 most visited websites in the world, Healthline is a media company engaged in the use of use of online tracking technology on its website. The online trackers used on Healthline’s website, like cookies and pixels, communicate data about readers to advertisers and other third parties in order to maximize ad revenue. That data uniquely identified consumers along with, for example, titles of articles they were reading. Some titles indicated that the reader may have already been diagnosed with a serious illness, such as “You’ve Been Newly Diagnosed with MS. What’s Next?” In some cases, according to the allegation, consumers often had no idea how many online trackers might be running.

The settlement includes strict injunctive terms, such as:

  • A ban on sharing article titles that could imply a diagnosis.
  • Enhanced user opt-out mechanisms for data sharing.
  • Stronger contractual safeguards with service providers and third-party advertisers.

Key Takeaways for Business

For businesses that collect or share consumer data, especially when using online tracking technologies that share sensitive categories like health information, this case is just another reminder about the potential compliance and litigation risks. Here are some best practices for businesses subject to the CCPA.

  1. Audit data practices, including identifying what personal information, as well as sensitive personal information, the business is collecting and how it is being used and shared.
  2. Be familiar with what tracking technologies are being used on your websites, including what information they collect and share.
  3. Strengthen opt-out mechanisms, including ensuring that the “Do Not Sell or Share My Personal Information” link is prominent and functional.
  4. Review third-party contracts with advertisers and analytics providers, including CCPA-compliant data use restrictions.
  5. Avoid inadvertent disclosure by being cautious about URLs, article titles, or metadata that could reveal personal information.

Conducting an annual review of CCPA compliance, as required under the CCPA, is an obvious step to help ensure ongoing compliance.

Tags: CCPA, heatlh-related data, metadata, opt-out, sensitive personal information, third party contracts
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Photo of Joseph J. Lazzarotti Joseph J. Lazzarotti

Joe has had the honor of being a part of the AmLaw 100, nationwide law firm, Jackson Lewis, which has 60+ offices around the country, for nearly 25 years. After practicing in the northeast for most of his career, Joe is resident in…

Joe has had the honor of being a part of the AmLaw 100, nationwide law firm, Jackson Lewis, which has 60+ offices around the country, for nearly 25 years. After practicing in the northeast for most of his career, Joe is resident in the firm’s growing Tampa office.

In 2005, as an associate, Joe founded and currently co-leads the firm’s national privacy, cybersecurity, and AI practice groups, which touts 25+ attorneys navigating complex and emerging challenges, particularly around the collection, use, disclosure, and retention of personal information, the deployment of artificial intelligence, and overall governance, risk and compliance in these areas, including FTCA, HIPAA, NIST, CCPA, CPRA, BIPA, GIPA, NY SHIELD, CIPA, etc. Joe has handled hundreds of data breaches, stood up cybersecurity compliance programs, and established AI governance programs.

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