1. Get an accurate read of your organization’s data.
It is important to get a comprehensive understanding of the type and volume of data that your company collects and stores. To do this, companies should conduct regular audits and assessments to ensure they are in compliance with CPRA regulations. This process should include analyzing the sources from which data is collected, the method of data collection, and the purpose of collecting the data.
2. Create and implement classifications for your organization’s data.
Classifying data into categories based on its sensitivity or importance allows companies to better understand which data is subject to CPRA regulations and how it should be handled in accordance with those regulations. Companies can create categories such as “publicly available information”, “sensitive personal information”, and “private restricted-use information” to help them identify which type of security measures are appropriate for each dataset.
3. Take necessary remediation steps.
Organizations must take proactive steps to ensure they remain compliant with all CPRA requirements by addressing any potential data privacy or security issues that arise. This can include conducting risk assessments, implementing data security measures such as encryption, and providing regular training to staff on CPRA compliance.
4. Make Subject Rights Requests easy for consumers and for your team.
The CPRA gives individuals the right to request access to, correction of, deletion of, or restriction of their data from companies. Organizations must make it easy for customers to exercise these rights by providing a clear way for them to do so and creating processes for quickly responding to requests. The company should also have procedures in place for reviewing and approving any requests that are made before they’re fulfilled.
5. Create data governance and data classification policies.
Organizations need to develop policies and procedures for properly handling and protecting data in accordance with CPRA regulations. This includes creating policies on how data should be collected, stored, used, shared, or disposed of; establishing standards for security measures that must be applied to personal information; and instituting guidelines for responding to subject rights requests.
6. Develop a data retention strategy.
Organizations need to have a plan in place for determining how long certain types of data are kept as well as when it is appropriate to dispose of or delete it. Companies should also consider their legal obligations regarding the retention of customer data and ensure they meet these requirements.
7. Ensure your organization is transparent about the collection and use of customer data.
Companies should clearly communicate what type of data they collect, how it is used, and with whom it is shared in an easily accessible manner. This can include having a privacy policy or statement on the company’s website that is written in plain language which customers can easily understand.
8. Provide consumers an easy way to access, modify, or delete their personal data.
Organizations must provide customers with a simple way to access, update, or delete any of their personal information that has been collected. Companies should also consider providing customers with additional tools such as password resets and account deletion requests so they have full control over their data.
9. Ensure that any automated decision making systems are documented and transparent.
Organizations need to document any automated decision-making processes that are used to gather, process, or store customer data. This includes providing information about the algorithms and models being used, how the decisions are made, and any potential risks or biases associated with those systems. Companies should also ensure they keep up-to-date records of these automated decision-making processes and make them easily accessible by customers.
10. Implement proper security measures for all collected data.
Organizations must ensure that all collected data is stored securely and protected from unauthorized access or misuse. This includes regularly testing systems, implementing encryption technologies where appropriate, monitoring for potential breaches, and providing staff with adequate training on data protection best practices.