California Consumer Privacy Act (CCPA) Compliance Simplified
CCPA Has Unique Compliance Requirements:
Annual Cybersecurity Control Audits
Formal Data Protection Impact Assessments (DPIAs)
Reporting To Executive Leadership
Supported By
Minimize Legal Exposure To CCPA Audit Attestations
Based on company size, annual cybersecurity audit reporting for the California Consumer Privacy Act (CCPA) starts in 2028. This is an annual requirement to report no later than April 1st of each year on the entity’s recent cybersecurity audit findings to the California Privacy Protection Agency (CCPA).
The California False Claims Act (CFCA) is the legal minefield that Chief Information Security Officers (CISOs) face with inaccurate or fraudulent CCPA cybersecurity audit findings.
The Secure Controls Framework Conformity Assessment Program (SCF CAP) provides a path for businesses to obtain third-party validation of its cybersecurity controls to address the annual CCPA audit requirements. This conformity assessment provides CISOs with the assurance needed to report annual attestations to the state.
CCPA Audit Steps To Success: Plan, Do, Check & Act
Annual CCPA cybersecurity audit reporting starts in 2028, but it may take several years for entities to be audit-ready. This pre-audit work may identify necessary business process and technology changes - this is an opportunity for process improvements and operational efficiencies! This necessitates a Plan, Do, Check & Act (PCDA) approach to eliminate assumptions:
PLAN
Clearly understand the scoping of the cybersecurity audit and the applicability of each requirement as it applies to People, Processes, Technologies, Data & Facilities (PPTDF). Once the compliance scope is defined, the ownership of cybersecurity controls needs to be assigned to the appropriate stakeholders.
DO
Those “control owners” are responsible for implementing the necessary administrative, technical and/or physical controls necessary to demonstrate conformity. This includes creating necessary artifacts (e.g., outputs from procedures) to prove processes exist.
CHECK
The evidence of due diligence and due care that control owners generated need to be evaluated for validity. This helps eliminate assumptions that controls are properly designed and implemented through independent examination of evidence.
ACT
There is no expectation that processes will be perfect 24 x 7 x 365 and that is where your organization needs to act on identified deficiencies. This involves modifying technology processes as business processes evolve to stay compliant.
CCPA Audit Success = Content + Process + Technology
Successfully demonstrating CCPA compliance is one thing - it is entirely a different thing to do so efficiently and effectively. This is where there is a need to have the right content, processes and technologies to make CCPA compliance attainable.
CONTENT
The Secure Controls Framework (SCF) is a free resource that contains free cybersecurity controls with complete coverage for the CCPA cybersecurity requirements.
PROCESS
The SCF Conformity Assessment Program (SCF CAP) provides an efficient and cost- effective approach to a third-party audit for CCPA cybersecurity requirements.
TECHNOLOGY
Cyturus is the technology platform that can operationalize SCF controls to make compliance with CCPA as efficient as possible.
Third-Party CCPA Audit Service
Third-party audits reduce risk by providing an independent validation of available evidence to ensure sufficient evidence of due diligence and due care exists to attest to the CPPA that your organization conforms with CCPA cybersecurity requirements.
CCPA Article 9 - Cybersecurity Audit
Article 9 of the CCPA covers the requirements for entities to conduct annual cybersecurity audits:
CCPA Section 7120. Requirement to Complete a Cybersecurity Audit.
CCPA Section 7121. Timing Requirements for Cybersecurity Audits and Audit Reports.
CCPA Section 7122. Thoroughness and Independence of Cybersecurity Audits.
CCPA Section 7123. Scope of Cybersecurity Audit and Audit Report.
CCPA Section 7124. Certification of Completion.
CCPA Article 10 - Risk Assessments (Data Protection Impact Assessments)
Article 10 of the CCPA covers the requirements for performing Data Protection Impact Assessments (DPIAs) (e.g., risk assessments):
CCPA Section 7150. When a Business Must Conduct a Risk Assessment.
CCPA Section 7151. Stakeholder Involvement for Risk Assessments.
CCPA Section 7152. Risk Assessment Requirements.
CCPA Section 7153. Additional Requirements for Businesses that Process Personal Information to Train Automated Decisionmaking Technology.
CCPA Section 7154. Goal of a Risk Assessment.
CCPA Section 7155. Timing and Retention Requirements for Risk Assessments.
CCPA Section 7156. Conducting Risk Assessments for a Comparable Set of Processing Activities or in Compliance with Other Laws or Regulations.
CCPA Section 7157. Submission of Risk Assessments to the Agency.
Cybersecurity & Data Privacy Documentation For CCPA Compliance
ComplianceForge provides editable policies, standards and procedures that are mapped 1-1 to SCF controls. This provides necessary documentation to demonstrate compliance with CCPA.
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