CCPA7 min read

What is CCPA? A Complete Guide for Startups

The California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), is one of the most comprehensive privacy laws in the United States. For organizations handling personal information of California residents, understanding CCPA is essential for avoiding significant penalties and building customer trust.

Key Takeaways

Point Summary
What it is California's landmark privacy law granting consumers rights over their personal information
Effective date Original CCPA: January 1, 2020; CPRA amendments: January 1, 2023
Who it applies to For-profit businesses meeting revenue, data volume, or data sales thresholds
Revenue threshold $26.625 million or more in annual gross revenue (as of January 2025)
Maximum penalty $7,988 per intentional violation; $107-$799 per consumer for data breaches

Quick Answer: CCPA is California's consumer privacy law that gives residents the right to know, delete, correct, and opt out of the sale or sharing of their personal information. It applies to for-profit businesses with $26.625M+ revenue, 100,000+ consumers' data, or 50%+ revenue from data sales.

CCPA Overview

The CCPA was signed into law in 2018 and became effective on January 1, 2020. California voters approved the CPRA in November 2020, which significantly amended the CCPA with additional protections that took effect on January 1, 2023.

Aspect Details
Original Effective Date January 1, 2020
CPRA Amendments Effective January 1, 2023
Jurisdiction California residents
Enforcement Bodies California Attorney General, California Privacy Protection Agency (CPPA)
Maximum Penalty per Violation $7,988 (intentional) / $2,663 (unintentional)

The CPRA did not create a separate law. Instead, it amended the existing CCPA, which is why the combined law is typically referred to as "CCPA" or "CCPA, as amended."

Why CCPA Matters for Growing Companies

CCPA applies to businesses regardless of their physical location. If you have California customers or users, you may need to comply. For growing businesses, CCPA compliance tends to become relevant at several key inflection points.

Common reasons organizations prioritize CCPA compliance:

  • California market access. California represents the world's fifth-largest economy, and CCPA compliance is essential for serving this market.
  • Enterprise sales. B2B customers increasingly require CCPA compliance from their vendors, alongside frameworks like SOC 2 or ISO 27001.
  • Data breach liability. The private right of action for data breaches creates significant financial exposure for non-compliant businesses.
  • Regulatory scrutiny. The California Attorney General and CPPA actively enforce CCPA, with settlements reaching millions of dollars.
  • Privacy-first positioning. Consumers increasingly favor organizations that demonstrate responsible data handling practices.

Who Must Comply with CCPA?

The CCPA applies to for-profit businesses that collect California consumers' personal information, do business in California, and meet any of the following thresholds. For a detailed breakdown, see our CCPA applicability guide.

Threshold Details
Revenue $26.625 million or more in annual gross revenue (adjusted January 2025)
Data Volume Buy, sell, or share personal information of 100,000+ California consumers or households
Data Revenue Derive 50% or more of annual revenue from selling or sharing California consumers' personal information

Important clarifications:

  • The revenue threshold is based on worldwide gross revenue, not just California revenue.
  • Non-profit organizations and government agencies are generally exempt.
  • The law applies regardless of your business location if you have California customers.

What is Personal Information Under CCPA?

The CCPA defines personal information broadly as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular consumer or household.

Category Examples
Identifiers Name, email, phone number, Social Security number, IP address
Commercial Information Purchase history, products considered, consuming histories
Internet Activity Browsing history, search history, interaction data
Geolocation Data Physical location, GPS coordinates
Employment Information Current or past job history, performance evaluations
Education Information Student records (non-FERPA covered)
Inferences Consumer profiles, preferences, characteristics

Sensitive Personal Information

The CPRA introduced a special category called sensitive personal information with heightened protections:

SPI Category Examples
Government IDs Social Security number, driver's license, passport number
Financial Access Account numbers with passwords or security codes
Precise Geolocation GPS-level location data
Protected Characteristics Race, ethnicity, religion, union membership
Private Communications Contents of mail, email, or text messages
Biometric Data Fingerprints, facial recognition, voice prints
Health Information Medical history, conditions, treatments
Sexual Orientation/Life Sexual orientation, sex life information
Genetic Data DNA, genetic test results
Immigration Status Citizenship and immigration status (added 2024)

Key CCPA Terminology

Term Definition
Consumer A California resident (not limited to customers)
Business For-profit entity meeting CCPA thresholds
Service Provider Entity processing data on behalf of a business under contract
Contractor Third party with access to personal information under written contract
Third Party Entity that is not a business, service provider, or contractor
Sale Transferring personal information for monetary consideration
Sharing Transferring personal information for cross-context behavioral advertising
Processing Any operation performed on personal information

CCPA vs. Other Privacy Laws

Aspect CCPA GDPR VCDPA (Virginia)
Jurisdiction California EU/EEA Virginia
Scope For-profit businesses meeting thresholds Any organization processing EU data Businesses meeting thresholds
Consent Model Opt-out for sales/sharing Opt-in required Opt-out model
Right to Delete Yes Yes Yes
Right to Correct Yes (CPRA) Yes Yes
Private Right of Action Yes (data breaches) Limited No
Maximum Fine $7,988 per violation €20M or 4% global revenue $7,500 per violation

Common Misconceptions

"We're too small for CCPA"
CCPA has specific revenue and data thresholds, but many growing companies meet the 100,000+ consumer threshold faster than expected, especially those with online products.

"We're not in California, so CCPA doesn't apply"
CCPA applies to any business meeting the thresholds that collects California residents' data, regardless of where the business is located.

"We just need a privacy policy"
CCPA requires operational capabilities including consumer request handling, opt-out mechanisms, data inventory, and vendor contracts, not just documentation.

"CCPA only matters if we sell data"
The CPRA expanded the law to cover "sharing" for advertising purposes. Many businesses that don't "sell" data still share it for cross-context behavioral advertising.

"CCPA compliance is a one-time project"
Compliance requires ongoing maintenance, including responding to consumer requests within deadlines, updating disclosures, and training staff.

The Business Case for CCPA Compliance

Benefit Impact
Risk Mitigation Avoid penalties up to $7,988 per violation and data breach lawsuits of $107-$799 per consumer
Market Access Serve California's 39+ million residents and the fifth-largest economy globally
Customer Trust Demonstrate commitment to privacy, increasingly important to consumers
Competitive Positioning Meet vendor requirements for enterprise customers
Operational Clarity Data inventory and mapping improves overall data governance
Breach Preparedness Security requirements reduce breach likelihood and impact

How Bastion Helps

CCPA compliance involves navigating complex requirements across legal, technical, and operational domains. Working with experienced partners can help organizations achieve compliance more efficiently.

Challenge How We Help
Understanding applicability Assessment of thresholds and scope specific to your business
Privacy policy updates Compliant notice templates and review processes
Consumer request handling Workflows and systems for request verification and fulfillment
Vendor management Service provider contract templates and tracking
Ongoing compliance Monitoring, training, and evidence collection
Security requirements Guidance on reasonable security measures and breach response

Ready to explore your CCPA compliance options? Talk to our team →


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