How can you prepare for the CPRA data privacy framework in Information Systems?

1 Understand the CPRA scope and obligations

The CPRA applies to any business that collects or sells personal information of California residents and meets one of the following criteria: has annual gross revenue of more than $25 million, buys, sells, or shares the personal information of more than 100,000 consumers or households, or derives more than 50% of its annual revenue from selling or sharing personal information. The CPRA also creates a new category of sensitive personal information, such as biometric data, health information, financial information, and geolocation data, that is subject to additional restrictions and opt-out rights. The CPRA also imposes new obligations on businesses, such as conducting data protection impact assessments, appointing a privacy officer, and maintaining reasonable security measures.

3 Revise and enhance your privacy policies and notices

The CPRA requires businesses to provide consumers with clear and comprehensive privacy policies and notices that inform them of their rights and choices regarding their personal information. You should review and revise your privacy policies and notices to ensure that they comply with the CPRA requirements and reflect your current data practices. You should also enhance your privacy policies and notices to include more details about your data protection impact assessments, your privacy officer, your retention periods, your opt-out mechanisms, and your contact information. You should also make your privacy policies and notices easily accessible and understandable to your consumers.

4 Implement and test your consumer rights requests and responses

The CPRA grants consumers several rights over their personal information, such as the right to access, delete, correct, opt-out, and limit the use and disclosure of their personal information. You should implement and test your systems and processes for receiving, verifying, and responding to consumer rights requests in a timely and compliant manner. You should also ensure that you have the technical and organizational capabilities to fulfill the consumer rights requests and to communicate with the consumers and any third parties involved in the data processing.

6 Monitor and adapt to the CPRA developments and enforcement

The CPRA establishes a new California Privacy Protection Agency (CPPA) that will have the authority and resources to enforce the CPRA and issue regulations and guidance. You should monitor and adapt to the CPRA developments and enforcement and stay updated on the CPPA actions and decisions. You should also review and audit your information systems and data practices regularly and make any necessary adjustments or improvements to ensure your ongoing compliance and security. You should also be prepared to demonstrate your compliance and accountability to the CPPA and the consumers in case of any inquiries or investigations.

7 Here’s what else to consider

This is a space to share examples, stories, or insights that don’t fit into any of the previous sections. What else would you like to add?