CCPA COMPLIANCE CHECKLIST

CCPA compliance checklist

A practical CCPA / CPRA compliance checklist covering personal-information inventory, privacy notice, consumer rights request workflow, vendor agreements, and staff training - the operational backbone for California consumer privacy obligations.

Who must comply with CCPA / CPRA

Who CCPA / CPRA applies to

Businesses that do business in California and meet at least one CCPA threshold: $26,625,000+ in annual revenue (CPPA-adjusted as of 1 January 2025), 100,000+ California consumers / households, or 50%+ of revenue from selling personal information.

Jurisdiction: Businesses subject to California consumer privacy law. Full name: California Consumer Privacy Act, as amended by the CPRA.

CCPA / CPRA Checklist

The CCPA / CPRA compliance checklist

The high-level cycle. Each item below is the visible head of a fuller process - open it in the editor to flesh out the steps, owners, and decisions your team actually runs.

The PDF includes real fillable form fields - tick each checkbox in your PDF reader and fill in organisation name, owner, and dates. The DOCX is fully editable in Word, Google Docs, or any compatible editor.

  1. STEP 1

    Confirm CCPA applicability and document the basis (revenue threshold - $26.625M+ as of 1 Jan 2025, consumer count of 100K+, or 50%+ revenue from sale of PI).

  2. STEP 2

    Inventory the personal information you collect, the sources, the purposes, and disclosures.

  3. STEP 3

    Publish a CCPA-compliant privacy notice covering all required disclosures (CCPA § 1798.100).

  4. STEP 4

    Stand up a "Do Not Sell or Share My Personal Information" link and signal-honouring mechanism.

  5. STEP 5

    Build the consumer rights request workflow - Know, Delete, Correct, Opt-Out, Limit Use of SPI.

  6. STEP 6

    Implement identity verification proportionate to the request type and the data sensitivity.

  7. STEP 7

    Update vendor agreements with service-provider / contractor / third-party terms.

  8. STEP 8

    Train staff on intake, verification, and the 45-day response window (extendable by 45 days).

  9. STEP 9

    Log all consumer requests, response times, and outcomes for the metrics report.

  10. STEP 10

    Annual review and update for legislative or regulatory changes.

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CCPA / CPRA compliance checklist

California Consumer Privacy Act, as amended by the CPRA

Organisation

[Organisation name]

Owner

[Assigned to]

Target date

[Target completion date]

Reviewed by

[Reviewed by]


Confirm CCPA applicability and document the basis (revenue threshold - $26.625M+ as of 1 Jan 2025, consumer count of 100K+, or 50%+ revenue from sale of PI).

Inventory the personal information you collect, the sources, the purposes, and disclosures.

Publish a CCPA-compliant privacy notice covering all required disclosures (CCPA § 1798.100).

Stand up a "Do Not Sell or Share My Personal Information" link and signal-honouring mechanism.

Build the consumer rights request workflow - Know, Delete, Correct, Opt-Out, Limit Use of SPI.

+ 5 more checkboxes in the downloaded PDF
CCPA / CPRA Process Map

CCPA / CPRA as a process map

The operational CCPA programme as a process map - inventory, notice, rights workflow, vendor agreements, and staff training. The vendor-agreement step is the one teams underestimate; a single service provider with the wrong contractual terms re-classifies them as a third-party sale.

Open in editor

CCPA / CPRA consumer rights request workflow

A CCPA / CPRA consumer rights request workflow rendered as a BPMN 2.0 process map. The flow receives a request, verifies the consumer identity per §1798.140(y), branches on request type (access, delete, correct, opt-out of sale or sharing), fulfils or denies with a permitted reason, tracks the 45-day SLA (extendable once by 45 days), responds to the consumer, and logs the outcome to the disclosure metrics required by §999.317.

  1. Receive a verifiable consumer request via at least two designated channels (toll-free number + website or email).
  2. Verify the consumer's identity per §1798.140(y) and §999.323 - matching data points proportional to the sensitivity of the request.
  3. If the consumer cannot be verified, deny the request, explain why, and treat any Delete request as an opt-out of sale or sharing instead.
  4. If verified, identify the right invoked - access, delete, correct, or opt-out of sale or sharing - and fulfil it via the relevant downstream system.
  5. Track the 45-day SLA (extendable once by 45 days with notice to the consumer) for substantive responses; opt-out of sale or sharing must be honoured within 15 business days.
  6. Respond to the consumer with the fulfilment output or a permitted denial reason (e.g. legal hold, security exception, deletion exemption under §1798.105(d)).
  7. Log the request, verification method, decision, response date, and any extensions in the consumer-rights request register for the §999.317 disclosure metrics.
CCPA / CPRA FAQ

Frequently asked questions

Is the CPRA a different law from the CCPA?

The California Privacy Rights Act (CPRA) is a 2020 ballot measure that amended and expanded the CCPA, effective 1 January 2023. The combined regime is often called "CCPA / CPRA" or just "CCPA". The CPRA added rights (Correct, Limit Use of Sensitive PI), restructured "sale" into "sale or share", and established the California Privacy Protection Agency.

Do I need to honour Global Privacy Control (GPC) signals?

Yes. The CPPA has confirmed that businesses subject to the CCPA / CPRA must honour GPC signals as a valid opt-out of sale or share for the browser sending the signal.

What is the difference between a "service provider" and a "third party" under CCPA?

A service provider processes personal information on the business's behalf under a CCPA-compliant contract that restricts use to the disclosed business purposes. A third party is everyone else - and disclosure of PI to a third party is treated as a "sale" or "share" requiring opt-out. The vendor contract language is what determines which bucket a recipient falls into.

How long do I have to respond to a consumer rights request?

Confirm receipt within 10 business days; substantively respond within 45 calendar days. You can extend by an additional 45 days where reasonably necessary, with notice to the consumer.

More Compliance Checklists

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Turn the CCPA / CPRA checklist into a working process

Open the CCPA / CPRA process map, rename the steps to match your organisation, and turn the checklist into a working procedure your team can run year after year.