CCPA Compliance Checklist (This is All You Need)

CCPA is one of the most stringent compliance frameworks there is. This marks a significant shift where consumers have more access than ever to control how their personal data is processed.

So, if your business is  collecting data on California residents, you must ask yourself, “When am I gonna get compliant.” However, don’t rush it; before you go into the official audit, there are some steps you can take to make it much easier.

By the end of the article, you will be ready to achieve CCPA compliance with no hiccups on the way. Read on to learn about CCPA Compliance Checklist!

What is CCPA Compliance?

The California Consumer Privacy Act (CCPA) grants your consumers the rights concerning (the collection, use, and sale) of their personal data. It also bars service providers from discriminating against them for exercising these rights. This law applies to organizations operating in California that meet specific criteria.

Surprisingly, this law is young; it was enacted in June 2018 in response to numerous cases of businesses mishandling or misusing private/sensitive data.

When it came to effect finally, it held down the roots of how businesses should have a legitimate purpose for collecting personal information. It allows Californians to easily request, delete, or safeguard their personal data managed by service providers.

So, to whom does it apply? Let’s see it below before diving into the CCPA checklist…

To whom does the CCPA compliance checklist apply to?

CCPA compliance applies to businesses under special circumstances. Unlike GDPR, which covers any organization that deals with personal information from any EU citizen, CCPA applies to businesses that engage with California residents and meet one of three criteria.

Personal information includes social security, email address, name, etc. This is why consumers have rights, access requests, and explicit consent to be CCPA compliant. This is why you need a CCPA checklist to keep up with security practices and legal obligations.

• Annual gross revenue exceeding $25 million
• Dealing with the personal information of 50,000 households or more consumers or devices for commercial purposes
• Earning 50 percent or more of their annual revenue through the sale of personal information

Also check: 5 Best CCPA Compliance Tools

Suppose your company meets any of these. In that case, you need to inform consumers about the type of personal information you collect and its purpose during data collection as a part of privacy rights and privacy regulation.

CCPA Compliance Checklist: Key points to keep in mind

We advise you to go through the checklist carefully and note whether it is already implemented. Please keep in mind that the act places various obligations on your company. 

Here is the 10-point CCPA checklist we’ve outlined for you:

1. Is your company in the purview of CCPA?

Asking this question is very important. It’s because CCPA doesn’t apply to government agencies, non-profits, or businesses already regulated by other privacy laws like HIPAA.

But if your company operates in California and falls outside those categories, you need to comply with CCPA if you meet any of these conditions:

• If your annual revenue exceeds $25 million for-profit business.
• If you buy, sell, receive, or share personal information for commercial purposes from 50,000 or more California residents, households, or devices.
• If over 50% of your company’s revenue comes from selling personal information.

Companies that don’t meet these criteria aren’t obligated to adhere to CCPA. However, considering CCPA compliance can benefit future growth or strengthen your corporate social responsibility initiatives.

2. Build your personal information inventory

Ok, the next step in the CCPA requirements checklist is to create a Personal Information Inventory. This is quite easy as it qualifies as personal information under CCPA and documents it.

To secure this data, you must chart the path of all Personally Identifiable Information (PII) you process and store.

Again, you must identify the systems, devices, and networks with sensitive personal information. Any data that can relate to, identify, describe, or be linked to an individual or consumer should be safeguarded by CCPA regulations.

3. Conduct data collection audits

This helps you get a deep understanding of the personal information you gather, how it’s stored, used, sold, or shared, and who within your company has access to it.

To simplify this process, use a compliance automation platform with a continuous control monitoring feature. And Sprinto is the best for this. The Continuous Monitoring Platform does not rely on samples but analyzes the full data sets.

Exceptions can be identified in real-time and dealt with swiftly and effectively (instead of the current practice of corrective actions that take weeks or months after the actual exception has occurred).

4. Revise your privacy policies

This is where you have to create a privacy policy; it’s important to keep in mind not to Create just any CCPA privacy policy checklist but to create one that is in line with the CCPA requirements checklist.

Also, keep in mind that you must update it once every 12 months with proper consent notice and/or consent from minors.

When creating the policy, avoid using jargon. Make sure your privacy policy is easy to understand.

What should be mentioned in the CCPA privacy policy checklist?

• Clearly specify the types of personal information you collect and the reasons behind this data collection (categories of information collected)
• Explain how consumers can exercise these CCPA privacy measures.
• Explain how and why you use this personal information (purposes of collecting personal information as a part of consumer privacy rights).
• Include your contact details so consumers can easily get in touch with any questions or concerns.
• If you sell consumer data, provide details about who receives this personal information and for what purposes (categories of information sold)
• Outline the rights consumers have under the CCPA, such as the right to know what personal information is collected about them, the right to request deletion, and the right to opt out of data sales (consumer rights)

5. Process the requests

As you prepare for CCPA compliance, the privacy part of the framework comes with its own guidelines and exceptions. Hence, you need to create a response plan in advance that helps you reduce the risk of errors.

Here is the list of request processing checklists you need to follow:

• Put in place a system that allows your consumers to request access to their data or if they want to delete it
• Now, this is not a drill; make sure to respond within 45 days or face the consequences
• The requests can happen through online portals, toll-free numbers, or email channels
• Make sure you have a way to confirm the requestor’s identity

6. Add an opt out button

You need to add an opt-out button. This minimizes manual updates. Since you are involving yourself in selling your consumers’ personal information, add a straightforward process for consumers to opt-out. The disclaimers on your website should include something like “Do Not Sell My Personal Information.”

This way, those who are not interested can easily opt-out themselves.

7. Come up with an incident response plan

Nothing is perfect; that’s why you need a proper plan to fall back on in case of emergencies. Usually, the problems that arise with CCPA violations are stolen personal information or privacy breaches. This plan can be a standalone process or integrated into your broader risk management strategy.

Here’s how to go about it as a part of compliance requirements:

• Assign specific responsibilities to relevant stakeholders within your company to avoid intentional violation
• Create a clear incident response process in case any CCPA-related breaches occur and be safe from reputational damage
• Conduct regular training and drills to prepare your team for responding to potential incidents and be safe from unauthorized access

8. Educate your employees

To make sure everyone in your team has a clear understanding of CCPA requirements, conduct routine training sessions. This is particularly important for employees who deal with consumer inquiries.

For example, imagine you run an e-commerce business. The requirement for businesses here would be that your customer support team handles requests from California residents about their personal data. Training sessions will help them understand CCPA regulations. 

If you didn’t train them about direct consent or consent preferences, there are chances that they might delay the inquiries to more than 45 days as well.

This is where Sprinto comes in with its security training modules as well. You can customize the training according to the framework and other policy requirements. 

9. Record all your consumer requests

You must maintain detailed records of all consumer requests and their resolutions, retaining this information for 24 months at least. Hence, start documenting all the papers where the customer requests something and when you address it.

It serves as a critical means of demonstrating your compliance, especially in the event of audits or inquiries.

For instance, picture a financial institution that receives requests from customers to access or delete their personal data under CCPA. Keeping records of these requests and how they were handled is essential for proving compliance should regulators or auditors inquire.

10. Use automation platforms

Manually tracking CCPA-compliant privacy policy is unmanageable, and we hear you on this. Tracking the right to delete, request information, and incident response plans can be overwhelming.

Remember that the CCPA doesn’t demand regular audits. But it’s your job to maintain ongoing data security and CCPA control monitoring. The most efficient way to go about this is by investing in a compliance automation platform.

And Sprinto will be your champion here. With effective features like continuous control monitoring, common control mapping, risk management, and automated evidence collection, you’re looking to automate compliance tasks up to 90%.

List of consumer rights you must know under CCPA

Your business’s responsibility is to inform consumers about CCPA consumer rights. We have listed the rights individually to help you address them in your CCPA privacy policy checklist.

• The right to rectify inaccurate personal information
• The right to access collected personal information
• The right to be informed about personal information collection
• The right to opt out of data sharing, processing, and selling
• The right to limit the use and disclosure of sensitive personal information
• The right to opt out of automated decision-making tech
• The right for minors to opt in
• The right to data portability
• The right to non-discrimination and protection against retaliation
• The right to request the deletion of personal data from the collecting business and any third parties it shared the data with

Check out the difference between CCPA and GDPR

Sprinto to the Rescue! 

Many businesses fall under the scope of CCPA compliance regulations and are obligated to achieve compliance. Some steps, like updating privacy policies or data deletion, may be very simple.

However, even a single instance of non-compliance can pave the path to consequences like paying hefty civil penalties. These instances could be as harmless as forgetting to respond to a customer query within a specific period. 

Hence, relying on traditional compliance methods might not help you get your best foot forward since they are not built to deliver efficiently in this fast-paced world with a million moving parts. It could set your CCPA progress back by months. Fortunately, efficient solutions (compliance automation) exist for achieving CCPA compliance promptly. 

Sprinto offers an automated solution that can guide your business toward full CCPA compliance standards in weeks without requiring expensive legal consultations or technical deployments. From evidence collection to monitoring how each control is performing, Sprinto will save you 100+ man hours, which otherwise would be spent on core business processes. 

Reach out to our team to explore how we can assist your company in achieving compliance swiftly. 

FAQs

1. How CPRA is related to CCPA?

The CPRA is related to the CCPA because it is an amendment of the CCPA. The CPRA has published a provision that states that it can amend the provisions of the CCPA. Here, amending refers to adding new provisions.

2. What requirements does the CCPA impose on employers?

The main requirement CCPA imposes on employers is that businesses must provide notice before they even collect personal information on consumers. It can be at the time of collection, too. It applies to the employer whether they sell, use, or share the PI with anyone.

3. What information is exempt from CCPA?

The information exempt from CCPA is the maintenance, disclosure, communication, or sale of personal information. However, this exemption does not apply to the breach liability provision.

4. What rights do the CCPA and CPRA give to California consumers?

Under the CCPA and CPRA, California consumers have the following rights:

• The right to be informed about the personal information you collect along with its usage and sharing
• The right to request the deletion of personal information you collect from them, with certain exceptions
• The right to opt out of the sale or sharing of consumers personal information

5. What is the importance of CCPA compliance checklist?

CCPA compliance checklist is important because it will give you an idea of what you can expect in the certification process and the scope of your company’s exploration in understanding the controls to implement with reasonable security measures.

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