In March 2025, Honda Motor Company got a $632,500 wake-up call. That’s when the California Privacy Protection Agency fined the automotive giant for violating the California Consumer Privacy Act (CCPA).
The agency found that the company required customers to provide too much of their personal information, made it too hard for them to exercise their right to privacy, and shared personal data with advertising technology companies without proper disclosures.
The case wasn’t about the typical data breach that often triggers regulatory action; it was about failing to protect consumer privacy in the first place. And it highlights a critical reality. More than just another compliance checkbox, the CCPA represents a shift in how businesses must handle consumer data, with real financial consequences for those who fail to comply.
This guide will walk you through everything you need to know about the CCPA, from basic definitions to practical compliance steps, helping you protect both your customers’ privacy and your business.
What Is the CCPA?
The California Consumer Privacy Act (CCPA) is a state privacy law that took effect on January 1, 2020. It made California the first U.S. state to establish sweeping consumer privacy protections. The law was designed to give California residents unprecedented control over their personal information and how businesses collect, use, and share that data.
The CCPA emerged from growing concerns about data privacy violations and the misuse of personal information by large technology companies. It establishes a framework similar to the European Union’s General Data Protection Regulation (GDPR), with some key differences.
In 2020, California voters approved the California Privacy Rights Act (CPRA), which significantly expanded the CCPA’s protections and created the California Privacy Protection Agency (CPPA) as a dedicated enforcement body. The enhanced regulations took effect in March 2023, strengthening consumer rights and increasing business obligations.
Who Does the CCPA Apply To?
The CCPA applies to for-profit businesses that gather personal information from California residents and also:
- Have annual gross revenue of more than $25 million (adjusted for inflation)
- Purchase, sell, or share personal information on 100,000 or more consumers or households
- Realize 50% of their annual revenue through the sale of consumer personal information
Importantly, businesses don’t need to be physically located in California to fall under the CCPA’s jurisdiction. Any company that does business in California and meets these criteria must comply, regardless of where they’re headquartered.
CCPA’s extraterritorial reach means businesses across the United States and internationally may need to implement CCPA compliance measures.
The law defines “consumers” broadly to include any California residents, whether they’re in the state temporarily or permanently. That includes employees, job applicants, and independent contractors. Nonprofits and government agencies are exempt.
What Personal Information Is Covered?
The CCPA takes an expansive approach to defining personal information. It covers any information that “identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.”
The definition includes traditional identifiers such as:
- Names, addresses, and phone numbers
- Email addresses
- Online identifiers such as IP addresses
- Social Security numbers
- Driver’s license numbers
But the CCPA goes further, also protecting:
- Biometric information, including fingerprints and voiceprints
- Internet activity, including browsing history and search records
- Geolocation data from mobile devices and applications
- Professional and employment information
- Education records that aren’t publicly available
- Commercial information, including purchase histories and preferences
- Sensory data, including audio, visual, thermal, and even olfactory information
- Inferences drawn from personal information to create consumer profiles
Consumer Rights Under the CCPA and CPRA
The CCPA grants California residents a number of fundamental rights regarding their personal information, including the following.
Right to Know
Consumers can request detailed information about what personal data a business has collected about them, including:
- Types of personal information collected
- Business purposes for collecting the information
- Identities of third parties with whom information is shared
- Specific pieces of personal information collected
Right to Delete
Businesses must delete personal information upon request from California residents, unless specific exemptions apply. For example, companies may retain data when necessary to complete transactions, detect security incidents, comply with legal obligations, or when they can’t verify a deletion request.
Right to Opt-Out
Consumers have the right to opt out of a company selling or sharing their personal information with other parties. The CCPA defines “sale” to include any disclosure of personal information for valuable consideration, which can include advertising revenue from data-sharing arrangements.
Right to Non-Discrimination
Businesses cannot discriminate against consumers who exercise their CCPA rights by denying goods or services, charging different prices, or offering different service levels. However, differences are allowed if they are reasonably related to the value of the consumer’s data.
CCPA Compliance Requirements for Businesses
Meeting CCPA obligations requires businesses to implement comprehensive privacy practices, including in the following ways.
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- Privacy policy requirements mandate that businesses maintain detailed privacy policies that outline their data collection, use, and sharing practices.
- Notices at collection are required before or at the time of collecting personal information.
- Opt-out mechanisms must be clearly and easily accessible for consumers to opt out of the sale or sharing of their personal information.
- Protections for minors mean that businesses cannot sell or share personal information for consumers under 16 without opt-in consent. Children under 13 must receive parental consent.
- Response procedures must be in place to respond to rights requests within 45 days.
- Reasonable security measures must be implemented to secure personal data against unauthorized access, sharing, or handling.
How to Become CCPA Compliant: Step-by-Step Guide
Rather than viewing CCPA compliance as a one-time project, successful businesses treat it as an ongoing process that touches every aspect of how they collect, use, and protect personal information. Here’s a roadmap.
Perform a Data Audit
Begin with a complete audit of the personal information your company collects, processes, and transmits.
Map data flows from collection points through storage systems to third-party partnerships. Mapping can start with a simple paper-and-pencil exercise, making the exercise accessible to even non-technical staffers.
Document the business purposes for each type of data collection and identify all parties who have access to consumer information.
Implement Opt-Out & Disclosure Mechanisms
Develop clear and accessible methods for consumers to exercise their rights. This includes adding prominent “Do not sell or share my personal information” links to your website, implementing universal opt-out signals such as Global Privacy Control, and establishing processes for handling rights requests.
Update Your Privacy Policy
Revise your privacy policy to include all CCPA-required disclosures. Specify what personal information you collect, why you collect it, how you use it, and with whom you share it. Include clear explanations of consumer rights and instructions for exercising those rights.
Train Staff and Document Processes
Educate employees who handle personal information about CCPA requirements, particularly customer service representatives who may receive consumer requests. Document your compliance procedures and maintain records of privacy-related activities for potential regulatory review.
CCPA Cookie Compliance Explained
The CCPA significantly impacts how businesses use cookies and similar tracking technologies. Many cookies constitute personal information under the law, particularly when they create unique identifiers that can be linked to specific consumers or households.
Recent court decisions have expanded interpretations of CCPA violations to include situations where websites allow third parties, such as search and social media companies, to embed tracking technologies that collect user information. As with any other personal data, businesses must provide opt-out mechanisms for these activities and respect consumer preferences.
Businesses should clearly disclose their use of tracking technologies within their privacy policies. These disclosures should include details about what data is being collected and shared with third parties.
Understanding Penalties for Non-Compliance
Penalties for CCPA violations can add up quickly. The California Privacy Protection Agency may impose fines of up to $2,500 per unintentional violation and $7,500 per intentional violation or violation involving minors under 16.
Beyond regulatory penalties, the CCPA provides consumers with a private right of action for data breaches involving unauthorized access to unencrypted personal information. Consumers can seek damages of $100 to $750 per incident or more if they can prove that actual damages are higher.
Recent court decisions have expanded the scope of the private right of action beyond traditional data breaches. Courts have allowed CCPA claims to proceed against companies whose websites intentionally shared personal information with third parties through cookies and tracking technologies without proper consent.
Before pursuing legal action, consumers must provide businesses with 30 days’ written notice to cure violations. This cure period offers companies an opportunity to address compliance issues before facing litigation.
Official Resources for CCPA Guidance
Cppa.ca.gov is the primary source of information on CCPA guidance and enforcement, including:
- Detailed regulations and interpretive guidance
- Explainers and compliance guides
- Frequently asked questions for businesses and consumers
The California attorney general’s office also maintains resources for consumers at oag.ca.gov/privacy/ccpa, including definitions of consumer rights and rules for responding to consumer requests.
For businesses seeking professional development, organizations like the International Association of Privacy Professionals (IAPP) offer U.S.-specific training and certification programs to help privacy professionals stay current with evolving requirements.
Given the law’s complexity and ongoing evolution, if you have significant data processing activities, consider consulting with privacy-focused legal counsel to ensure full compliance.
Also, consider partnering with a technology services provider with privacy and security-related expertise in your industry. Xantrion works with finance, law, manufacturing, life sciences, and other prominent industries in California.
CCPA vs CPRA: What Changed?
The California Privacy Rights Act (CPRA) significantly strengthened the original CCPA framework with:
- Enhanced consumer rights, allowing consumers to correct inaccurate information and limit the use of sensitive personal information for targeted advertising and profiling.
- Expanded enforcement, with dedicated resources for privacy enforcement and rule-making.
- Sensitive data protection, with new categories of sensitive personal information receiving heightened protection and specific opt-out rights for uses beyond necessary business purposes.
- Universal opt-out support requirements for businesses to recognize and honor browser-based privacy signals like Global Privacy Control as valid opt-out requests.
CCPA vs GDPR: Key Differences
While both the CCPA and GDPR aim to protect consumer privacy, they differ in some important ways, including in the following areas.
Geographic Scope
The GDPR applies to any business processing data related to residents of the European Union. In contrast, the CCPA focuses on businesses that meet revenue or data volume thresholds for California residents.
Legal Basis
The GDPR requires specific legal justifications for data processing, including unambiguous consent and covered legitimate interests, while the CCPA generally allows processing with appropriate notice and opt-out mechanisms.
Consent Requirements
The GDPR requires explicit consent for many processing activities, whereas the CCPA generally employs an opt-out model.
Penalties
GDPR fines can reach 4% of global annual revenue, while CCPA penalties are calculated per violation rather than as a percentage of revenue.
Data Subject Rights
Both laws provide similar rights, but the GDPR includes additional protections, such as data portability and the right to object to the processing of personal data.
International companies may be subject to both privacy frameworks, making cross-jurisdictional coordination essential.
Becoming a Privacy-First Business for Long-Term Success
The California Consumer Privacy Act marks a fundamental shift in how companies doing business with Californians must approach consumer data privacy. Its broad reach and significant fines, such as the one imposed on Honda, mean that businesses can’t afford not to take it seriously.
Whether you’re collecting customer emails for marketing, using cookies for website analytics, or sharing data with advertising partners in the State of California, the CCPA likely impacts your company’s operations.
On the upside, companies that proactively embrace CCPA’s requirements not only stand to avoid costly penalties but also create stronger customer trust, building competitive advantages in an increasingly privacy-conscious marketplace.
Xantrion’s virtual CIO can help you navigate the complexities of CCPA compliance while building robust data protection practices that scale with your business. To learn more, contact us.
