CBLA Wins Privacy Protections for Angelenos in STAP Settlement

CBLA WINS PRIVACY PROTECTIONS FOR ANGELENOS IN STAP SETTLEMENT

In 2022, the City of Los Angeles approved the Sidewalk & Transit Amenities Program (STAP), which involved, among other things, the installation of bus shelters with digital displays at transit stops. But in reviewing the STAP contract, Citizens for a Better Los Angeles saw a number of red flags regarding the collection and sharing of data under the program. CBLA filed a lawsuit, primarily resting on the guarantee of the right to privacy granted by the California Constitution.

In 2025, CBLA agreed to a settlement with the City and the vendor, Tranzito-Vector (TV), which achieved greater privacy protections for Angelenos. Among the terms of the settlement were the following:

No personally identifying data shall be collected by wireless technology within any STAP elements.
Should STAP in the future offer publicly-accessible WiFi, no personal devices will be permitted to connect to public WiFi via any STAP element without affirmative consent of the device user, and no personal data shall be collected.
Should STAP in the future incorporate amenities such as transit fare payment, e-lockers, or scooter docking stations, any personally identifiable information collected through these features shall be handled in strict compliance with applicable privacy laws and City policies.

Elected officials are always looking for new revenue to augment city budgets. In recent years, outdoor advertising companies have been aggressively promoting digital advertising in the LA area (and in cities across the country). A number of local governments have signed agreements to allow the construction of digital billboards, digital kiosks and other digital displays, in exchange for a share of the revenue, which can be considerable.

Unfortunately, the outdoor digital advertising economy relies on the collection of massive amounts of data from personal devices, often without the consent of the device's owner. The apps on your phone can allow companies to collect your personal information and location data. These companies often share this information with data brokers or other third parties, and advertisers are especially anxious to get their hands on it. Digital out-of-home (DOOH) advertising refers to billboards, kiosks and other displays that we're increasingly seeing in public spaces. Through data collected in conjunction with digital ads, businesses can learn not only whether you've been exposed to a specific campaign, but also if you visited a store that carried the product and whether or not you bought it.

If the digital outdoor advertising ecosystem only allowed companies to send you targeted ads, you might ask why you should be concerned. The problem is, data brokers are collecting a wide range of data, which could include information about your health, political affiliation, religious beliefs, finances, and on and on. Because there's little effective regulation controlling how data brokers share or sell this information, once it makes its way into the data ecosystem, it's impossible to control who has access to it. Your data can easily be purchased by pretty much anyone who's wiling to pay for it.

That's why, when the City of LA approved the Sidewalk & Transit Amenities Program (STAP) in September, 2022, Citizens for a Better Los Angeles filed a lawsuit challenging the approval. Our primary purpose was to uphold Californians' right to privacy, which is guaranteed by Article I, Section I, of the State's Constitution. At the same time another group, Coalition for a Beautiful Los Angeles, filed a lawsuit against the program based on alleged violations of the California Environmental Quality Act.

Fortunately, after over two years of intensive discussions, both Citizens for a Better Los Angeles and Coalition for a Beautiful Los Angeles were able to arrive at settlement agreements that mitigated many of STAP's worst defects.

Citizens for a Better Los Angeles will continue to monitor local government programs that involve the collection and sharing of personal data. We will continue to insist that elected officials and private contractors respect the California Constitution's guarantee of the right to privacy.