CCPA Compliance Checklist

Published on : 09 Mar 2022

CCPA Compliance Checklist

California Consumer Privacy Act is a data privacy regulation established in the US. Achieving and maintaining compliance with the regulation can be overwhelming for organizations. But with the right understanding of the CCPA Compliance regulation and adhering to the compliance requirements, achieving compliance can be easy. So, explaining the regulation in detail we have shared an informative checklist that organizations can refer to as steps to achieve CCPA compliance. So, before getting into the details of the checklist, let us first learn about the regulation for a better understanding of the requirements.

What is CCPA Compliance?

California Consumer Privacy Act of 2018 (CCPA) which came into effect on January 1, 2020, is a regulation designed to protect the privacy rights of citizens of California. It is the first comprehensive law in the US that is established to protect the personal information of California residents. CCPA regulations promote security, transparency, and privacy of consumer’s data. It is seen as a regulation that mirrors EU GDPR in terms of the intent of its establishment and certain measures to secure data. CCPA regulation applies beyond California and applies to any for-profit business that falls in the scope of compliance.

CCPA applies to organizations, or businesses that are “for-profit”, serving and processing data of residents of California. Businesses that earn more than $25,000,000 gross annual income and buy, sell, process personal information of at least 50,000 California consumers, households, or devices annually fall in the scope of CCPA Compliance. Further, a business that makes 50% or more of the annual gross revenues from selling the personal information of the California consumers also falls in the scope of CCPA Compliance.

Now that we know a bit about the regulation let us understand how businesses can comply with CCPA and meet all the requirements of the regulation. 

CCPA Compliance Checklist

A. Create a Personal Information Inventory

Understanding what is defined as personal information under CCPA and creating an inventory for the same is a crucial part of the compliance process. Organizations need to map out the flow of all the data personally identifiable information (PII) stored and processed in the organization to secure the data. This would include identifying systems, devices, and network that comprises sensitive personal information. So, basically, any information that identifies relates to, describes, and is capable of being associated with a particular individual or consumer needs to be protected under the CCPA regulation. For this, identifying data, classifying them, and creating an inventory is an essential first step of the compliance process.

B. Create Policy, Procedures & Processes

Organizations need to have in place privacy policies, procedures, and processes to support the security and privacy measures for the compliance program. They should be drafted and documented in plain language so that consumers, employees, and other stakeholders can easily understand the content. Further, these documents should be reviewed periodically and updated from time to time.

C. Operational & Technical Security Measures

The prime focus of CCPA Compliance is to ensure the security and privacy of consumer data. So, implementing necessary measures to uphold the rights of consumers and protect their data is essential. For this, business needs to have a necessary security policy in place, implement encryption techniques and other security measures where applicable to ensure privacy and security of personal data. Identify the data stored, in systems, devices, and networks to accordingly implement security measures for consumer’s personal data. All of these security measures and appropriate steps are required for achieving and maintaining CCPA compliance. 

D. Uphold Consumer Rights

CCPA broadly outlines a list of consumer rights that organizations must uphold. On request, the organization must adhere to it and allow consumers to exercise their rights. CCPA allows the consumer rights over their personal information which includes Right to access, Right to portability, Right to deletion, Right to notice, Right to opt-out, Right to non-discrimination to name a few. Organizations should establish a policy and process to uphold these rights of consumers. 

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E. Consent for Minor

Protecting the information of minors is very important. There should be parental or guardian consent that should be provided on behalf of the minor. The consent received should be documented for future reference. There should also be an explicit grant for parents and guardians to access their children’s information when needed.

F. Ensure Transparency in Data Processing

Transparency is the key to CCPA Compliance. Organizations must ensure transparency in their data collection and processing operations. Customers should be informed or notified about the collection and use of their data clearly. They should also be given an “opt-out” option in case they wish to not allow processing and collection of their data. The “opt-out” option should be visible and easy to execute for all customers.  Pop-up window addressing the collection of personal information, and “Don’t Sell My Personal Information” should be clearly visible on the website. This demonstrates the organization’s efforts of upholding consumer’s privacy rights. 

G. User-friendly Information requests

Organizations should provide consumers information on ways to exercise their rights over their personal data. The request process should be easy, quick, and hassle-free for consumers. CCPA clearly outlines the need for organizations to provide an easy process for consumers to exercise their right over personal data.  Further, they should have a process in place to ensure quick response to requests from consumers who wish to access, delete or exercise any other right over their information. These processes need to be enforced with having necessary policies and procedures in place. All of this should further be documented and maintained for the compliance audit process and future reference. 

H. Respondto Requests in Time

CCPA law mandates the need for an organization to establish an effective process to respond to the request promptly. This would mean responding to all requests including access, delete, and opt-out of the sale to name a few. Organizations should be prompt in their response once they receive the request. For this organization needs to plan and establish a systematic process to support the requirement on time.

I. Compliance Training for Employees

Employees are an integral part of the organization and business processes. So, training employees and building awareness of the regulation and its requirements is essential. Employees need to be aware of the roles and responsibilities in line with the requirements of meeting CCPA compliance. For this, organizations should have regular training for employees to meet compliance requirements and handle customer’s data responsibly. Employees should also be given training on ways to handle customer inquiries pertaining to their rights to access their personal data. This is essential for CCPA requires organizations to respond to consumer’s requests promptly.

J. Internal Assessment & Review

Conduct an internal assessment and review process from time to time to ensure processes are in place and whether or not they are effective. This is important to ensure the organization has all measures in place and meets the CCPA requirements. It is during these internal assessments and reviews that organizations can identify gaps against the CCPA requirements and remediate the gaps in time.

Consider CPRA Compliance Gaps

California Privacy Right Act is the latest version of the California Consumer Privacy Act that was passed on November 3rd, 2020. It is said to take effect on January 1, 2023, enhancing California residents’ existing privacy rights and providing protection to consumers concerning how their personal information is used. So, for organizations to stay ahead of the compliance game, should conduct a CPRA gap analysis to identify gaps and bridge them on time. Organizations should conduct an assessment and accordingly plan and prioritize their implementation to fill the gaps and meet the CPRA requirements. 

Narendra Sahoo
Narendra Sahoo

Narendra Sahoo (PCI QPA, PCI QSA, PCI SSF ASSESSOR, CISSP, CISA, CRISC, 27001 LA) is the Founder and Director of VISTA InfoSec, a global Information Security Consulting firm, based in the US, Singapore & India. Mr. Sahoo holds more than 25 years of experience in the IT Industry, with expertise in Information Risk Consulting, Assessment, & Compliance services. VISTA InfoSec specializes in Information Security audit, consulting and certification services which include GDPR, HIPAA, CCPA, NESA, MAS-TRM, PCI DSS Compliance & Audit, PCI PIN, SOC2 Compliance & Audit, PDPA, PDPB to name a few. The company has for years (since 2004) worked with organizations across the globe to address the Regulatory and Information Security challenges in their industry. VISTA InfoSec has been instrumental in helping top multinational companies achieve compliance and secure their IT infrastructure.