What Is the CPRA? Real-World Scenarios to Understand California's Privacy Rights Act

CPRA Overview

The California Privacy Rights Act (CPRA) strengthens and expands California’s consumer privacy law. It builds on the CCPA and creates new obligations for businesses that meet certain thresholds, such as annual revenue, volume of personal information processed, or reliance on selling or sharing data for revenue.

The CPRA introduces purpose limitation, data minimization, and storage limitation. It adds a new category—sensitive personal information—plus new rights for consumers and a dedicated regulator, the California Privacy Protection Agency. If you operate in or target California, you should treat CPRA compliance as an ongoing program, not a one-time project.

Who the CPRA Covers

• For-profit entities doing business in California that meet statutory thresholds.
• Affiliates, service providers, contractors, and third parties handling personal information on behalf of covered businesses.

Core Compliance Building Blocks

• Clear notices at or before collection, accurate privacy policy disclosures, and documented retention periods or criteria.
• Contracts with service providers, contractors, and third parties that restrict data use and require security.
• Processes to authenticate requests and honor consumer choices across systems and partners.

Consumer Privacy Rights

Under the CPRA, Californians gain stronger control over their information. You must be ready to fulfill requests promptly and without discrimination against the consumer for exercising a right.

• Right to know/access: consumers can request details about categories and specific pieces of personal information collected, sources, uses, and disclosures.
• Right to delete: consumers can submit a data deletion request, which must flow down to relevant service providers and contractors.
• Right to correct: consumers can ask you to correct inaccurate personal information.
• Right to opt out of sale or sharing: consumers can opt out of selling or sharing data, including for cross-context behavioral advertising.
• Right to limit use/disclosure of sensitive personal information: consumers can restrict certain processing to essential purposes.
• Right to data portability and non-discrimination: provide data in a portable format and do not reduce service quality or charge unjustified fees for exercising rights.

Sensitive Personal Information

Sensitive personal information is a special category that warrants heightened protection. You must disclose how you use it and provide a clear way for consumers to limit non-essential uses.

Common Examples

• Government identifiers (e.g., Social Security, driver’s license, passport numbers).
• Financial account numbers with access codes, precise geolocation, and biometric identifiers.
• Racial or ethnic origin, religious or philosophical beliefs, union membership.
• Genetic data; health information; sexual orientation.
• Contents of mail, email, or text messages where you are not the intended recipient.

Practical Controls

• Display a clear “Limit the use of my sensitive personal information” option.
• Minimize collection; use SPI only for essential services (e.g., fraud prevention or account security).
• Mask or tokenize SPI where feasible, and segregate access with strong authentication and logging.

Enforcement by California Privacy Protection Agency

The California Privacy Protection Agency (CPPA) issues regulations, provides guidance, investigates complaints, conducts audits, and brings administrative enforcement actions. The California Attorney General also retains civil enforcement authority.

Expect scrutiny of your notices, contracts, preference signals, data retention practices, and your ability to demonstrate compliance. Maintain records that show how you verify requests, honor opt-outs, and limit sensitive personal data.

Operational Readiness

• Designate an owner for CPRA compliance and document policies and procedures.
• Test request-response workflows end to end, including identity verification and downstream vendor coordination.
• Continuously monitor adtech and analytics integrations for unauthorized sale or sharing.

Penalties for Non-Compliance

CPRA enforcement penalties can include civil fines of up to $2,500 per violation, and up to $7,500 for intentional violations or those involving children’s data. For certain security breaches, consumers may seek statutory damages (per consumer, per incident) or actual damages in private actions.

Penalties and remediation costs add up quickly when violations affect many consumers or persist over time. Investing in strong governance, vendor oversight, and security controls is far less costly than reacting after the fact.

Risk Reducers

• Data mapping and retention schedules tied to clear purposes.
• Vendor contracts with audit rights, data restrictions, and incident notification clauses.
• Routine self-assessments and employee training focused on privacy-by-design.

Unauthorized Sale of Personal Data Scenario

Imagine your retail app shares hashed emails and mobile IDs with an ad network for audience expansion. Marketing treats this as “service provider processing,” but the contract allows the network to reuse data for its own purposes. That is likely an unauthorized data sale or “sharing.”

What You Should Do

• Pause the integration and inventory all data flows to that partner.
• Reclassify the relationship: either implement service provider restrictions or treat it as a sale/sharing and honor opt-outs.
• Update consumer-facing disclosures to reflect the practice, and ensure a working “Do Not Sell or Share My Personal Information” mechanism.
• Implement and test Global Privacy Control (GPC) signal detection across web and apps.
• Notify affected consumers if your prior disclosures or opt-out tools were incomplete, and remediate preferences retroactively.

Data Breach Scenario

A phishing attack compromises an employee account with access to customer profiles and order history. Names, emails, addresses, and partial payment data may be exposed. Beyond security response, the CPRA lens matters because breach scope can trigger statutory damages risk and regulatory scrutiny.

What You Should Do

• Contain and investigate: disable access, rotate credentials, and review logs to pinpoint affected data.
• Notify consumers and relevant parties as required, provide clear guidance, and consider credit monitoring where appropriate.
• Evaluate vendor involvement and ensure contractors follow incident obligations.
• Harden controls: phishing-resistant MFA, least-privilege access, data segregation, and encryption at rest and in transit.
• Document decisions and timelines to demonstrate diligence to regulators.

Consumer Data Deletion Requests

When a consumer submits a data deletion request, verify identity and locate their records across systems and vendors. Delete personal information not subject to an exception and propagate the request to service providers and contractors.

Key Steps

• Authenticate the request using risk-appropriate methods; keep a minimal audit trail.
• Filter for statutory exceptions (e.g., security, legal obligations, warranty or transaction records, research, free speech).
• Execute deletion or de-identification, then confirm completion to the consumer.
• Update suppression lists so the consumer is not inadvertently re-collected for marketing.

Consumer Data Access Requests

Consumer data access requests require you to provide categories and specific pieces of personal information, sources, purposes, and categories of recipients. Deliver the response in a portable, readily usable format within applicable timelines.

Best Practices

• Centralize intake (web form, toll-free number, email) and track deadlines, typically 45 days with a permitted extension when reasonable.
• Validate identity and apply redaction: do not disclose highly sensitive personal data like full SSNs, account passwords, or security answers.
• Explain your data retention criteria and how the consumer can exercise other CPRA rights.
• Record decisions to demonstrate consistent, non-discriminatory handling of requests.

Opt-Out of Targeted Advertising

The CPRA lets consumers opt out of selling or sharing personal information for cross-context behavioral advertising. This includes use of identifiers and browsing data across different services to target ads.

Practical Implementation

• Provide an easily found “Do Not Sell or Share My Personal Information” control and honor GPC signals.
• Configure consent tools and tags to block adtech sharing until you have a valid basis to proceed.
• Reconcile preferences across web, apps, CDPs, and downstream partners; audit regularly.
• Update contracts to prohibit partners from reusing data for their own purposes without consumer choice.

Conclusion

The California Privacy Rights Act raises the bar on transparency, control, and accountability. By mapping data, tightening contracts, honoring opt-outs, and securing sensitive personal data, you protect consumers and reduce exposure to CPRA enforcement penalties.

FAQs.

What rights does the CPRA provide to consumers?

Consumers can know/access the personal information collected about them, request deletion, correct inaccuracies, opt out of the sale or sharing of their data (including for targeted advertising), limit the use and disclosure of sensitive personal information, receive data in a portable format, and be free from discrimination for exercising these rights.

How does the CPRA define sensitive personal information?

Sensitive personal information includes data such as government identifiers; financial account numbers with access codes; precise geolocation; biometric and genetic data; racial or ethnic origin; religious beliefs; union membership; health information; sexual orientation; and the contents of communications where the business is not the intended recipient. Consumers can require you to limit non-essential uses of this category.

Who enforces the CPRA in California?

The California Privacy Protection Agency leads rulemaking, audits, and administrative enforcement, while the California Attorney General retains civil enforcement authority. Both can pursue violations, so your program should be audit-ready and well-documented.

What are the penalties for violating the CPRA?

Regulators may seek up to $2,500 per violation and up to $7,500 for intentional violations or those involving children’s data. For certain data breaches, consumers can pursue statutory damages on a per-consumer, per-incident basis or actual damages, along with injunctive relief.