Essential Steps for CCPA Compliance in 2025
Meeba Gracy
Oct 04, 2023Back in 2018, the Californian Consumer Privacy Act (CCPA) came into effect, and it was a turning point for more than half a million companies operating in the US. However, consumers benefited the most here as CCPA set out to give users (especially Californian consumers) immense control over how their personal information was handled.
The CCPA’s primary focus is bringing transparency to California’s data-driven economic activities and educating consumers about their data rights.
Why comply with CCPA regulations specifically? And how do you know if CCPA applies to your business?
That’s what this article is about. Let’s dive in…
TL;DR
Under CCPA compliance, companies must comply with user requests by providing a full rundown of all the data they’ve collected and stored about that individual. |
CCPA kicks in for businesses that collect personal information from California residents, but only if they meet certain criteria. |
The CCPA spells out clear rules for businesses to protect consumers’ rights over their personal data, like postal addresses, email addresses, and any other info that can be used to identify them. |
What is CCPA Compliance?
California Consumer Privacy Act (CCPA) compliance mandates that businesses be transparent about the personal information they gather and how they process it. This law aims to empower individuals with greater oversight of their data and holds companies accountable for their privacy practices.
For example, if a user asks for all the data a company has collected and stored about them, the organization must provide it.
However, before diving into the CCPA regulations, understanding what constitutes personal data is paramount. The CCPA defines personal information as any data that can be indirectly or directly linked to a specific individual or household.
So what does personal info mean in this context? Personal information includes attributes like names, Social Security numbers, email addresses, and device identifiers such as IP addresses.
Need CCPA Compliance fast? We can help
Who needs to comply with CCPA compliance?
CCPA applies to businesses that collect personal information from California residents and meet certain prerequisites. There are 3 main criteria that determine the applicability of CCPA to a business. They are revenue threshold, data collection threshold, and business type.
Revenue & Data Collection Threshold
Businesses come under the purview of CCPA if they meet one or more of these revenue thresholds:
- If their annual gross revenue is $25 million or more.
- If they buy, sell, or receive Personal Information of 50,000 or more California residents or devices annually.
- If they Generate 50% or more of their annual revenue from selling the PI of California residents.
If your business satisfies any of these criteria, you must comply with CCPA regulations and consumer privacy rights, regardless of your geographical location (within or outside California).
For example, let’s say you sell a Content Management System, selling various products to customers across the United States, including California residents. Your business collects information like names, addresses, and purchase histories.
Here’s what you need to consider:
- Revenue: Check if your annual gross revenue exceeds $25 million. In this case, let’s say your business brings in $30 million a year. You fit the first criteria here.
- Data Collection: Examine whether you collect data from at least 50,000 California residents, households, or devices annually. Let’s assume you meet this threshold if your online store serves thousands of California consumers. You fit the second criteria as well
- Business Type: Your business is for-profit and operates online, making it a commercial entity. You fall into the category of businesses that need to comply with CCPA.
Given that your online business entity satisfies all 3 criteria, CCPA applies to you.
Also check out: 5 Best CCPA Compliance Tools
What are the CCPA compliance requirements?
The CCPA lays out specific requirements for businesses to follow to ensure that consumers’ rights regarding their personal data like postal address, email address, and other information that can be used for identification are safeguarded.
Here are the CCPA compliance requirements you need to know to if you are wondering how to be CCPA compliant to continue your business’s journey:
1. Check if your business fits the CCPA criteria
To figure out if you need to worry about CCPA compliance, first, check if your business fits the CCPA criteria. If your company operates for profit, does business in California, and meets at least one of these conditions:
- It makes more than $25 million in annual gross revenues,
- Deals with the personal information of 50,000 or more consumers, households, or devices,
- Or gets over 50% of its yearly income from selling people’s personal information,
Then, the CCPA applies to you. It’s important to nail down whether these factors apply to your business before starting the compliance process.
2. Take a closer look at your data sources
Next, figure out where your data originates from. Is it from consumers? Is it from the third-party vendors? Or is it from IoT devices or website cookies?
Once you recognize the origin story, understand its purpose, why you’re gathering each data type, and how you plan to use it. This step is critical to ensure that you don’t use data in ways the consumer doesn’t know about.
3. Pinpoint the personal information you gather
Start by identifying the personal information you are gathering on your consumers. The CCPA casts a wide net here, so be thorough and 100% sure. The data includes various categories spanning from names, email addresses, browsing history, and even geolocation data.
Hence, one of the best practices to be CCPA compliant is to document all consumer data your business collects and shares.
4. Be transparent about how you collect data
When you gather sensitive personal information, the CCPA mandates that you provide clear notice. This notice should state what data you’re collecting and what you’re collecting.
Also, keep your privacy policies up to date. Make sure they accurately reflect your current data practices and spell out the right consumers under CCPA. Don’t forget to update these policies regularly to comply with data regulations.
5. Follow the consumer rights
The CCPA mandates that the following consumer requirements be addressed. Here is the list of requirements:
6. Right to disclosure
When collecting a consumer’s data under CCPA protection, you must inform them of your intentions before or at the point of data collection. Simply put, you need to get your Californian consumer’s consent.
7. Right to access
Consumers have the right to request access to their data in an easily usable format, and this data should be provided free of charge within 45 days of the request. They should also have clear access to your full privacy policy.
8. Right to contact information
You must tell consumers where they can find more details about your privacy policy and CCPA compliance. Also, provide a toll-free phone number and online contact information for CCPA-related inquiries.
9. Right to be forgotten
If a consumer asks for their data to be deleted from their records, the CCPA mandates compliance. There are only limited exceptions when data deletion requests can be overridden. However, these circumstances are rare and often involve government intervention.
10. Opt-out of data sales and marketing
If you sell personal information, give consumers a chance to opt-out. Maintain a webpage with a clear opt-out option and a link to your privacy policy. They should also be able to decline data usage for future marketing efforts.
11. Right to fair treatment
You cannot discriminate against users based on their CCPA rights. Provide the same access and service to all consumers, regardless of their choices.
12. Periodic privacy policy updates
Update your CCPA privacy policy every 12 months. This keeps customers informed if you change your data handling practices.
How to become CCPA compliant?
The CCPA brings about significant changes for your business and how you handle consumer data. While you can still collect and use personal data, there’s now a need for open transparency and responsiveness to consumer requests.
Here are the 8 steps to become CCPA compliant:
1. Appoint a Data Privacy and Security Leader
Taking inspiration from GDPR, assign a dedicated individual or team who will be the point of contact for safeguarding data privacy from unauthorized access. This role can be filled by someone holding titles like Chief Privacy Officer, Data Privacy Officer, or Chief Data Officer who can take enforcement action.
2. Create a repository for third-party data and review it
Building an auditable data inventory and third-party processors is the next important step. It is a data roadmap that charts the flow of information through the different departments in your business.
Suppose your company has previously conducted this exercise for data belonging to EU residents (as required by GDPR). In that case, you’re likely in a good position to identify the location of your California data.
If your business collaborates with other companies to handle consumer data, reviewing and revising these contracts for CCPA compliance is vital.
You can do this step easily with the help of Sprinto dashboard. Sprinto’s experienced CCPA compliance experts simplify this process and help you incorporate standard legal language into your agreements.
Ensure your contracts address CCPA compliance, including:
- Data processing: Specify how third parties handle consumer data.
- Data rights requests: Outline their role in data rights requests and collaboration with your business.
Even if you have yet to conduct a global inventory, the existing data inventory can provide some insights into the potential locations of California-based data.
3. Revise your privacy policy and notices
Now that your dream team is set, it is time to revisit your existing privacy policy and amend it to prevent non-compliance instances that cause actual damages. Conduct a CCPA gap assessment to identify areas that need updating. Your revised policy should cover the rights granted by the CCPA and outline how you will handle/process these rights in different situations.
Also, ensure that the privacy notice you provide to consumers at the data collection point is up to date and offers info about data usage and its impact.
4. Establish data rights protocols
Make the new consumer data rights a focal point of your efforts. This means developing processes and protocols to handle consumer requests effectively.
For example, suppose a consumer invokes their Right to Be Forgotten. In that case, your IT team should be well-prepared, knowing precisely where the data is stored and having a streamlined process to delete it while notifying the consumer in compliance with CCPA standards.
Having these protocols in place ensures that the process is efficient and fully aligned with CCPA requirements when consumer exercises their rights.
5. Conduct risk assessment
Now comes a crucial step, and this is where you, as a service provider, might consider using a CCPA compliance software to ease the burden of manual tasks. You need to condu