What is CCPA Compliance? What Enterprises Need to Know

If you’re a big enterprise doing business in California, then California Consumer Privacy Act (CCPA) compliance is non-negotiable. But, while the CCPA is a stringent regulation, complying with it doesn’t have to slow your organization down or limit your ability to innovate. 

In this blog, we will go over the essentials of CCPA, including who it applies to and the regulation’s key provisions. Then, we will walk through steps enterprises should take to maintain CCPA compliance — and how to automate and streamline it.

What is CCPA (California Consumer Privacy Act)?

The California Consumer Privacy Act (CCPA) is among the most comprehensive data privacy laws in the United States. The CCPA provides California residents with greater transparency and control over their personal information, and it ensures businesses are held accountable for maintaining consumer data privacy.

The CCPA was first enacted in June 2018 and later followed by amendments to enhance its scope, including a September 2025 update. At its core, it ensures that Californians have the right to know what personal information is being collected, sold, or shared by companies. The regulation also grants individuals control over their data, including the ability to request access, deletion, or the choice to opt out of its sale.

Since its enactment, the CCPA has been enforced by California’s Attorney General. In 2023, this responsibility expanded to the governing agency known as the California Privacy Protection Agency (CPPA). 

Organizations are now required to provide accessible options (such as website disclosures) for consumers to opt out of data sales, request data access, and understand the purpose behind data collection. The act also imposes penalties for non-compliance, with fines of up to $7,500 per intentional violation and $2,500 for unintentional lapses. 

The CCPA, strengthened further by the California Privacy Rights Act (CPRA) amendments, continues to be a pivotal framework in US data privacy law.

What Does the CCPA Cover?

The CCPA is designed to protect the privacy rights of California residents. Here’s a quick overview of its core elements:

Consumer Rights 

The CCPA gives consumers important rights to control their personal data. With the introduction of the California Privacy Rights Act (CPRA), these protections have been expanded to provide even greater transparency and control. 

Here’s a breakdown of consumer rights under these laws:

• Right to Know: Request details about the personal data a business collects, uses, and shares.
• Right to Delete: Ask for your personal data to be erased.
• Right to Opt-Out: Refuse the sale of your personal data to third parties.
• Right to Non-Discrimination: Ensure businesses can’t penalize you for exercising these rights. 

The CPRA builds on the CCPA by enhancing protections, including stricter rules around sensitive personal information and the creation of the California Privacy Protection Agency (CPPA) to uphold these rights.

Data Covered 

The CCPA applies to personal data that identifies, relates to, or can reasonably be linked to a California consumer, household, or device. Businesses must ensure compliance for data collection, use, and sharing.

This essential framework empowers California consumers while urging businesses to prioritize data transparency and security.

Who Must Comply with the CCPA? 

Businesses must comply with the California Consumer Privacy Act (CCPA) if they conduct business in California and meet any of the following thresholds:

• Annual gross revenue: Exceeds $25 million.
• Data management volume: Buys, receives, sells, or shares the personal information of 100,000 or more consumers, households, or devices annually (increased from the previous threshold of 50,000).
• Revenue from personal information: Derives 50% or more of annual revenue from selling or sharing personal information.

If a business meets one or more of these criteria, CCPA compliance is mandatory. And that means they must implement robust data collection practices, clearly notify consumers of how and why their data is being collected, and honor consumer rights such as data access, deletion, and opt-out requests. For those partnering with third-party vendors, CCPA compliance should extend to the data practices of all collaborators to minimize risks of violations.

For additional details, you can refer to California Legislative Information Section 1798.140 for the full CCPA text.

Understanding the CCPA: Key Provisions Impacting Data Privacy Compliance

The California Consumer Privacy Act (CCPA) features several important provisions designed to protect consumer data and enhance transparency. These provisions require businesses to disclose, manage, and secure personal information while providing consumers with specific rights.

To support these goals, CCPA mandates the following key requirements for businesses:

Disclosure Obligations

To maintain CCPA compliance, businesses must disclose details about:

• The data they collect about consumers.
• The categories of sources from which this information is collected.
• The purposes for collecting or selling such information.
• Any third parties with whom the information is shared.

Consent and Opt-Out Requirements

Companies are required to provide clear, accessible tools like forms or buttons on their websites. Features like this allow users to easily opt-in or opt-out of data sharing. It gives users greater control over how their personal information is collected, used, and shared by the company. 

The September 2025 regulation update also implemented rights to access and opt-out of businesses' automated decisioning technology (ADMT), which processes personal information and uses computation in place of human decision-making. 

Data Handling Practices

Businesses are expected to use consumer data only for legitimate business purposes, such as:

• Auditing transactions.
• Fraud detection and security monitoring.
• Debugging software issues.
• Providing short-term, transient services.
• Other activities performed on behalf of the business or service provider.

Cybersecurity Audits

The approved regulations and updates in September 2025 — which went into effect January 1, 2026 — require that certain businesses processing personal information must audit their cybersecurity program. (To see the CCPA compliance requirements and if you're one of those business that must conduct a cybersecurity audit, please refer to article 9, section 7120 of the CCPA.) 

⚖️ See an array of data privacy regulations and requirements at a glance >> Data Privacy Laws and Compliance: What You Need to Ensure Compliant Non-Production Data

What are the Penalties of Violating the CCPA?

The penalties of violating the CCPA are steep. Failure to address a violation within 30 days of notification can result in fines of up to $2,500 per unintentional violation and up to $7,500 per intentional violation. (It’s also important to note that organizations have 45 days to respond to any verified consumer request under the CCPA.)

Additionally, if the case of an unauthorized data breach, consumers can file a private right of action to claim damages of up to $750 per incident. 

That isn’t the entire cost of CCPA non-compliance, though. In addition to fines, companies can face lawsuits and reputational damage.

CCPA vs. GDPR: Key Similarities and Differences

The CCPA is often compared to the EU’s General Data Protection Regulation (GDPR). That’s because GDPR was enacted first, in 2018, and is considered a leader in consumer data privacy protections.

Both the CCPA and GDPR aim to enhance data privacy and give citizens more control over their personal information. But despite their similarities, each regulation has unique focuses and applications. 

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Key Similarities 

• Data rights for individuals: Both the CCPA and GDPR grant individuals the ability to access, modify, or delete personal data.
• Transparency requirements: Companies must communicate clearly about the data collection, use, and sharing practices.

Key Differences 

• Scope: GDPR governs all entities handling data of EU citizens, regardless of location. The CCPA applies only to organizations that conduct business in California and that meet specific thresholds.
• Penalties: GDPR enforces higher fines than the CCPA.
• Protected Scope: GDPR focuses solely on individual data, whereas CCPA extends protections to household data as well.

The State of Data Compliance (and Non-Compliance) Today

A growing number of organizations have suffered breaches in non-production environments, intensifying security and compliance concerns across every industry.

According to the 2025 State of Data Compliance and Security Report:

• 60% of organizations experienced data breaches or theft in non-production environments — an 11% increase from 2024.
• 30% cite CCPA as a primary compliance obligation for non-production data.
• 95% are storing more sensitive data in non-production than they did the year before. 

Discover more insights around sensitive data, compliance, masking, AI, and more from the 280 global leaders surveyed in the State of Data Compliance and Security Report. 

Get the Data Compliance Report

The Hidden CCPA Risk: Non-Production Environments 

While most organizations focus CCPA compliance efforts on production systems, non-production environments pose an equally critical risk. These environments often contain full copies of production data, including sensitive information from California residents, yet typically lack the same security controls. 

The numbers in our 2025 State of Data Compliance and Security Report tell a concerning story. Despite 95% of respondents report being moderately concerned about data breaches, 84% of organizations still allow compliance exceptions. 

A single breach in a test environment containing unmasked California consumer data could trigger the same CCPA penalties as a production breach. 

7 Steps Enterprises Should Take to Maintain CCPA Compliance

Complying with CCPA requirements is a non-negotiable for businesses operating in or catering to California residents. Below, we outline six steps for effectively maintaining CCPA compliance.

Step 1: Designate a Data Privacy Leader

Designate an individual or team to be in charge of data privacy and security.

For most of the companies we work with, CCPA compliance is designated to InfoSec teams. These teams report into the Chief Security Officer or Chief Data Officer, who is the data privacy leader. Together, this team typically sets up standards and all data classification elements. 

Step 2: Perform a Data Inventory

Map out all the personal data your organization collects, processes, and stores. Track data flows across all departments — how it's used, where it's stored, and who it's shared with — including non-production environments. This inventory should cover the origins of data, the purpose of its collection, and the systems or third parties involved.

According to research, 90% of organizations feel confident they can identify all sensitive data in non-production environments. But confidence alone isn't enough. With 95% reporting that their masking policies apply to multiple non-production environments, comprehensive data discovery tools are essential. Automated discovery ensures you don't miss sensitive data hidden in complex schemas or across multiple sources. 

Step 3: Assess and Document Risks

Evaluate the risks associated with your data handling processes. Identify potential vulnerabilities, such as insecure data storage locations or inappropriate access controls. Assess how these risks align with CCPA guidelines. Documenting these risks provides a clear pathway to mitigating issues while preparing your organization for regulatory scrutiny or consumer inquiries. Once a risk or issue has been mitigated, put checks in place to make sure it stays that way. 

The data in the report validates this approach: 95% of organizations now use static data masking to protect sensitive information in non-production environments. Many organizations are realizing that masking data in non-production environments eliminates many of the risks of CCPA non-compliance, as they do not have to worry about data vulnerabilities. A lot of health care customers we’ve worked with have taken this approach.

Step 4: Add Opt-Out Options To Your Website

If it doesn’t already, make sure your website provides simple, accessible tools for users to manage their data preferences. These features should allow consumers to opt out of data sales and give or withdraw consent for data collection. These data collection controls should be clear and user-friendly.

Step 5: Implement Robust Data Protection Measures 

Locate and remove personal information from non-production environments such as testing and development. Use data masking tools like Perforce Delphix to automatically identify and irreversibly mask data, then quickly deliver it for development, testing, analytics, and reporting. 

Additionally, establish policies to limit data access to only what’s necessary for business functions. Train employees regularly on handling personal data in a way that meets CCPA compliance requirements. Consider employing zero trust principles when working with any personal data.

Organizations face a common misconception that protecting data will slow down innovation. But modern data masking solutions can maintain data realism and referential integrity while accelerating delivery. The key is choosing an automated, scalable solution like Delphix that integrates seamlessly into your existing workflows. 

Step 6: Enforce Vendor and Third-Party Accountability 

Review contracts with vendors and third-party providers to ensure proper language around CCPA compliance. Shift responsibility for data protection to vendors by requiring adherence to applicable laws and specifying liability for breaches. Perform annual audits of your vendor relationships to verify they meet the necessary privacy obligations. Employ risk assessment surveys to track and maintain vendor accountability.

Step 7: Maintain Audit Trails and Record-Keeping 

Given that 68% of organizations express concern about privacy and compliance audits in the report, maintaining comprehensive documentation is more important than ever.

Document every aspect of your CCPA compliance program, from initial data inventory to employee training sessions. Keep detailed audit trails of consumer data requests and your organization’s responses. This practice not only ensures transparency but also provides a ready defense in case of regulatory inquiries or potential litigation.

CCPA Compliance and AI Adoption

As organizations increasingly adopt AI practices, CCPA compliance becomes more complex. California consumer data used to train AI models pose unique risks. Models can memorize and reproduce sensitive information in unexpected ways. 

The State of Data Compliance and Security Report reveals significant concern in this area: 78% of organizations are highly concerned about theft or breach of model training data. 68% also worry about privacy and compliance audits related to AI development. Yet, many organizations continue using sensitive data in AI environments. 

For CCPA compliance, the solution is clear: California consumer data must be masked or replaced with synthetic alternatives before entering AI training pipelines. 25% of organizations using static data masking are already applying it to AI model training and fine-tuning — a best practice that protects California consumer privacy while still allowing your teams to work with high-quality datasets. 

Ensure CCPA Compliance with Perforce Delphix Data Masking

Navigating data privacy regulations like the CCPA can be complex, but Perforce Delphix makes compliance simple and efficient. With advanced data masking capabilities, Delphix automatically identifies and anonymizes sensitive information, such as personal and financial data. It ensures your organization meets regulatory requirements while enhancing data security.

Related blog >> What is Delphix?

How Delphix Helps You Comply with CCPA

• Prevent Data Re-identification: Delphix uses deterministic and irreversible masking algorithms, ensuring that data cannot be reverse-engineered or re-identified, a key concern under CCPA. In the State of Data Compliance and Security Report, 81% of organizations rate static masking as highly effective for preventing sensitive data breaches.
• Comply with Privacy Requirements: Protect consumer data and comply with key privacy laws, including CCPA, GDPR, HIPAA, and PCI DSS, with centralized masking policies that span enterprise-wide. Organizations using Delphix protect 77.2% more data and data environments compared to manual approaches.*
• Simplify Audits: 100% of organizations have a data masking mandate — or will have one soon. Delphix provides audit logs and reporting on masking operations, enabling clear documentation for internal reviews and regulatory audits.
• Reduce Risk Across Non-Production Environments: Transform sensitive data into de-identified yet usable equivalents, eliminating exposure risks in environments such as development and testing.  
• Accelerate Data Delivery: Although 54% of organizations believe data protection slows development, Delphix demonstrates that speed and security can coexist. Combine data masking with virtualization to deliver safe, masked data to downstream teams faster and with greater efficiency.  

How Sky Italia Achieved Compliance in 5 Months

Sky Italia, a leading European media company, achieved compliance with GDPR in just five months using Delphix. By masking production data and accelerating development cycles, they reduced their infrastructure footprint by over 90% and operational costs by 30%. Read their story to see how they did it — and how your organization could achieve similar results while quickly complying with CCPA.

Read Sky Italia’s Story

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With Delphix, compliance and business growth do not have to be at odds. Mitigate compliance risks and leverage secure data for innovation without compromising privacy.  

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*IDC Business Value White Paper, sponsored by Delphix, by Perforce, The Business Value of Delphix, #US52560824, December 2024