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California (CCPA/CPRA) Privacy Law Compliance

California has the most mature US state privacy regime — the original CCPA (2020) plus the CPRA amendments (2023) that added sensitive personal information, the right to correct, sharing as a distinct concept from selling, and the California Privacy Protection Agency. As of March 2024 the CPPA is actively enforcing, with Sephora ($1.2M), DoorDash ($375K), and Tilting Point ($500K) already settled. Any business collecting data on California residents — even with no California operations — should treat CCPA/CPRA as the floor.

Statute
California Consumer Privacy Act / California Privacy Rights Act
Cal. Civ. Code §1798.100 et seq.
Effective
CCPA effective Jan 1, 2020
CPRA amendments effective Jan 1, 2023; enforcement Mar 29, 2024
Enforcer
California Privacy Protection Agency
(CPPA) + California Attorney General
Consumer rights
9
9 business obligations
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Who must comply

Exemptions

Consumer rights (9)

Right to access / know
Confirm whether personal data is processed and obtain a copy in a portable format
Right to delete
Request deletion of personal data the controller has collected
Right to correct
Correct inaccurate personal data
Right to data portability
Receive data in a portable, machine-readable format
Right to opt out of sale
Opt out of the sale of personal data to third parties
Right to opt out of targeted advertising
Opt out of cross-context behavioural advertising
Right to opt out of profiling with legal effect
Opt out of automated decisions producing legal or similarly significant effects
Right to limit use of sensitive PI
Restrict processing of sensitive personal information to disclosed purposes
Right against discrimination
Not be denied service or charged more for exercising privacy rights

Business obligations (9)

Public privacy notice
Clear, accessible notice of categories collected, purposes, third parties, rights, and contact channel
Rights response within 45 days
Respond to consumer rights requests within 45 days (extendable by 45 more with notice)
Data processing agreements
Written contracts with processors restricting their processing to the controller's documented instructions
Data protection assessments
Document risk assessment for targeted advertising, sale, profiling, sensitive data processing
Conspicuous opt-out mechanism
Clear opt-out link/mechanism in the footer and at point of collection
Honour universal opt-out signals (GPC)
Recognise the Global Privacy Control browser signal as a valid opt-out (where required)
Reasonable security practices
Administrative, technical, physical safeguards appropriate to the data's sensitivity
Data minimisation + purpose limitation
Collect only what is adequate, relevant, and reasonably necessary for the disclosed purposes
Children & teen consent
Opt-in consent before selling or sharing data of minors (age threshold varies 13–16)

Required privacy notice elements

  1. Categories of personal information collected (12-month lookback)
  2. Categories of sensitive personal information (separate disclosure)
  3. Business or commercial purpose for each category
  4. Categories of sources
  5. Categories of third parties to whom PI is disclosed, sold, or shared
  6. Consumer rights enumerated with how-to-exercise instructions
  7. 'Do Not Sell or Share My Personal Information' footer link
  8. 'Limit the Use of My Sensitive Personal Information' footer link
  9. Retention period for each category
  10. Date of last update (review every 12 months)
  11. Toll-free number or designated method to submit requests (businesses with online + offline)
  12. Authorised agent process
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Penalties

Civil penalty — unintentional violation
Up to $2,500/violation
Cal. Civ. Code §1798.155
Intentional violation OR violation involving minor
Up to $7,500/violation
§1798.155
Private right of action (data breach only)
$100–$750/consumer/incident OR actual damages
§1798.150
Sephora (CA AG, 2022)
$1.2M
Failed to honour GPC + Do-Not-Sell signal
DoorDash (CA AG, 2024)
$375,000
Selling PI without proper opt-out

Common compliance pitfalls

'We do not sell PI' while running Meta/Google Ads
Cross-context behavioural advertising IS 'sharing' under CPRA — a separate concept from 'selling'. If your site fires Meta Pixel or Google Ads Conversion tags, you almost certainly share PI and need the opt-out link plus GPC recognition.
Ignoring the Global Privacy Control signal
California explicitly requires controllers to respect GPC as a valid opt-out. This is the violation that earned Sephora a $1.2M settlement. Verify your CMP fires the opt-out on detection.
Using a pre-CPRA policy
The 2018 CCPA policy is missing: sensitive PI category, right to correct, sharing as separate from selling, retention disclosures, contact agent process. Auditors will spot a stale policy in seconds.
Treating employee data as out of scope
The Jan 2023 sunset of the B2B + employee exemptions means HR data is fully in scope. You need a separate employee privacy notice + rights workflow.

FAQ

Does CCPA apply to my out-of-state business?
Yes if you collect personal information from California residents AND meet one of the thresholds ($25M revenue, 100K+ CA records, or 50%+ revenue from selling/sharing PI). Physical presence in California is not required.
How is sharing different from selling?
Selling = exchange of PI for monetary or other valuable consideration. Sharing = disclosing PI for cross-context behavioural advertising (whether or not money changes hands). CPRA made sharing a separate opt-out so behavioural ads can't hide behind the 'we don't sell' loophole.
Who is the CPPA?
The California Privacy Protection Agency — the first dedicated state privacy regulator in the US, created by CPRA. It has rulemaking + enforcement authority alongside the California Attorney General.

Related state laws

Colorado (CO)
CPA
Connecticut (CT)
CTDPA
Virginia (VA)
VCDPA

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