Don’t let your organization’s compliance with the California Privacy Rights Act (CPRA) slip through the cracks.
Even though it’s a California-based regulation, you still need a plan for CPRA compliance if your organization processes
the personal information of California residents or conducts business in the state. And because other states have
implemented similar privacy laws, including Colorado, Connecticut, Utah and Virginia, organizations operating within
those states (or anticipating imminent privacy laws in their own state) should also begin to prepare.
Here’s what you need to know about the CPRA and some steps you can take to work toward compliance.
What Is the CPRA?
The CPRA is a comprehensive privacy law that strengthens and builds upon the privacy protections previously enforced by
the California Consumer Privacy Act (CCPA). Effective January 1, 2023, the CPRA expanded the definition of personal
information to include a new category of sensitive personal information and precise geolocation. It also establishes new
consumer rights and includes an independent regulatory body called the California Privacy Protection Agency.
If the CPRA applies to your organization, you could face administrative fines in the event of non-compliance — up to
$2,500 for each violation and up to $7,500 for each intentional violation.
Key CPRA Components
The CPRA includes a wide range of provisions that strengthen rights for consumers but also present new obligations for
businesses. There are three key components to CPRA that are particularly important to keep in mind:
- Data subject rights: The CPRA expands the data subject rights previously granted by the CCPA, such as the right to
access and delete personal information. It also introduces new rights, like the right to correct inaccurate information
and the right to limit use and disclosure of sensitive personal information.
- Employee protections: The CPRA extends protections to employees, job applicants and independent contractors, providing
them with privacy rights related to the collection, use and sharing of their personal information.
- Independent regulatory oversight: The California Privacy Protection Agency was established to implement and enforce
the CPRA privacy laws, including overseeing audits, conducting investigations, imposing penalties for CPRA violations
and ensuring that organizations that improperly process personal information are held accountable for their actions.
5 Actions That Can Help You Improve CPRA Compliance
The CPRA is complex and navigating the requirements can seem overwhelming. But getting up to speed sooner rather than
later can help you avoid potential fines, penalties and reputational damage that could come with noncompliance. Here are
five critical steps you can take now to help your organization align with CPRA regulations:
- Appoint a team of privacy experts: Your organization should assemble a dedicated team of privacy experts responsible
for conducting a comprehensive assessment of current privacy practices and creating a plan to ensure compliance.
- Establish a data inventory: A comprehensive personal data inventory helps your organization understand the personal
data you have, where it’s stored and how it is being used. Begin by identifying all the personal data you process,
including sensitive personal data.
- Improve your strategy for cybersecurity and data privacy: Bolstering your cybersecurity and privacy protocols now
will help you avoid future financial and/or reputational consequences. Your business should take appropriate
cybersecurity measures to protect personal data against unauthorized forms of processing. Additionally, if you have
global operations, it is crucial to implement a proper global privacy strategy from the outset, to consider not only the
CPRA but also to ensure that your organization is compliant with global privacy standards like the General Data
Protection Regulation (GDPR).
- Aim for more effective privacy management and look to close gaps: Create a plan to take control of your cybersecurity and privacy management by addressing existing gaps, providing corresponding solutions and applying a “privacy by design”
approach (i.e., protecting data through technology design).
- Train employees regularly: Make sure employees who handle personal data complete training programs and refresher
courses on CPRA and other applicable privacy frameworks so that they can better understand their responsibilities. When
your employees undergo the same training, you maintain consistent CPRA compliance across your organization.
Final Thoughts
Complying with the CPRA is crucial for organizations that process the personal information of California residents. By
understanding the CPRA, and taking the steps outlined above, you can put the right controls in place to protect personal
information, enhance data subject rights, build trust with customers and stakeholders — and demonstrate your commitment
to privacy and data protection.
Contact our data privacy experts to learn more about how to achieve CPRA compliance, or explore other ways to embrace
change and face the future with clarity.
