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California Privacy Rights Act (CPRA) Compliance Checklist: What You Need to Know

The General Data Protection Regulation (GDPR) set the stage for a new era of data protection and privacy compliance and effectively sparked a regulatory movement in the United States, along with the passage of the California Privacy Rights Act (CPRA).

With CPRA in effect and other privacy laws about to become active, organizations must ensure compliance while there is still time to address any gaps.

As high-profile cases and increasing regulations demonstrate, we are entering a new era of data management that is forcing companies to rethink how they collect, store, retain, access, and dispose of data. The General Data Protection Regulation (GDPR) set the foundation for modern data privacy compliance and triggered a global regulatory movement, including the California Consumer Privacy Act (CCPA) and later the California Privacy Rights Act (CPRA), passed in November 2020.

Since then, multiple U.S. states have introduced comprehensive privacy laws, giving organizations time to prepare their data governance and retention strategies—but that window is quickly closing.

Failure to comply with these increasingly complex regulations can result in significant financial penalties and reputational damage. Organizations must establish a defensible approach to privacy compliance and ensure their e-discovery and information governance programs are robust and effective.

The Costs of Non-Compliance

The financial and legal risks of failing to comply are substantial:

Data breach settlements can reach tens of millions of dollars
Organizations meeting certain thresholds (e.g., revenue, volume of personal data, or data sales) must comply with CPRA
Fines can reach:
- $7,500 per intentional violation
- $2,500 per unintentional violation
Data breach damages range from $100 to $750 per affected individual

Key Consumer Rights Under CCPA & CPRA

Right to know what data is collected and why
Right to access and correct personal data
Right to delete personal data
Right to know which third parties receive data
Right to consent to data collection and sharing
Right to opt out of data sales
Right to equal treatment

Key Regulatory Requirements

Consumer Notices

Organizations must provide clear, accessible notices, including:

Notice at data collection (purpose limitation)
Opt-out notice for data sales
Notice of financial incentives
Updated privacy policy with detailed disclosures
Disclosure of sensitive data usage and retention periods

Consumer Requests

Organizations must make it easy for individuals to exercise their rights:

Provide at least two request methods (e.g., web form, phone)
Confirm requests within 10 business days
Fulfill requests within 45 calendar days
Respond to opt-out requests within 15 business days
Notify third parties within 90 days
Maintain request records for 2 years

Request Verification

To prevent unauthorized data access:

Verify identity using existing data, accounts, or third-party services
Avoid collecting additional sensitive information during verification
Apply stricter verification for sensitive or large data requests

Data Breach Provisions

Data breaches carry heavy penalties and risks:

$100–$750 per affected individual
Large-scale breaches can result in massive financial exposure
Reputational damage can be equally severe

Expanded Enforcement Under CPRA

Increased fines for violations involving minors
Creation of the California Privacy Protection Agency (CalPPA)
Expanded definition of personal data breaches

Data Retention & Minimization

CPRA introduces strict requirements similar to GDPR:

Data Minimization

Data must be limited to what is necessary and proportionate
New uses require additional consumer consent

Retention Obligations

Organizations must define and enforce retention periods
Storing unnecessary data increases legal and financial risk

Cybersecurity & Third-Party Obligations

Organizations must:

Implement appropriate security measures to protect data
Ensure third-party vendors meet the same privacy standards
Prevent unauthorized data use, sharing, or disclosure

Why Data Retention Matters

Although storing data is inexpensive, over-retention creates major risks:

Increased costs during litigation and investigations
Greater exposure in case of data breaches
Regulatory penalties for retaining unnecessary data

Key considerations:

Could excessive retained data be exposed during legal requests?
Can unnecessary data be safely deleted to reduce risk?

You Can’t Afford to Over-Retain Data

Many organizations retain far more data than necessary
A large portion of stored data contains sensitive information
Over-retention increases liability and regulatory exposure

With CPRA enforcement, organizations face penalties not only for breaches but also for retaining data beyond its intended purpose.

Final Takeaway

Compliance with CPRA is no longer optional. Organizations must prioritize:

Strong data governance frameworks
Enforced data retention and deletion policies
Transparent consumer rights processes

Preparing for CPRA compliance also strengthens broader Governance, Risk, and Compliance (GRC) efforts—making it a critical investment in both regulatory readiness and long-term data management strategy.

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