Understand the critical differences between CCPA and CPRA with this comprehensive comparison guide. Learn what changed, new requirements, and how to ensure your business stays compliant with California's evolving privacy landscape.

If you're doing business with California consumers, you've probably heard the acronyms CCPA and CPRA thrown around. But here's the thing—many business owners are still confused about what actually changed when the California Privacy Rights Act (CPRA) amended the California Consumer Privacy Act (CCPA).

I've spent the last few years helping businesses navigate this transition, and I can tell you that the confusion is understandable. The CPRA isn't just a minor update—it's a significant evolution that fundamentally changes how businesses must handle California consumer data.

Let me walk you through exactly what changed, what it means for your business, and how to ensure you're fully compliant with California's current privacy landscape.

What Changed When CCPA Became CPRA: A Timeline Overview

The story begins in 2018 when California passed the CCPA, which went into effect on January 1, 2020. But even before businesses fully adapted to CCPA, California voters approved Proposition 24 in November 2020, which created the CPRA.

Here's where it gets interesting: the CPRA didn't replace the CCPA—it amended it. Think of CPRA as CCPA 2.0, with significant upgrades and new requirements that took effect on January 1, 2023.

The transition period was crucial. While CPRA's enforcement began in 2023, businesses needed to start collecting data under the new requirements as early as January 1, 2022, because CPRA applies retroactively to data collected 12 months prior to a consumer request.

From my experience working with clients during this transition, the businesses that started preparing early had a much smoother compliance journey than those who waited until the last minute.

Key Differences Between CCPA and CPRA: Side-by-Side Comparison

Let me break down the most significant differences in a way that actually makes sense for your business:

Scope and Thresholds

CCPA (Original):

  • Applied to businesses with $25M+ annual revenue
  • Or those buying/selling personal info of 50,000+ consumers
  • Or deriving 50%+ revenue from selling personal information

CPRA (Current):

  • Same revenue threshold ($25M+)
  • Increased consumer threshold to 100,000+ consumers annually
  • Maintained the 50% revenue threshold
  • Added specific thresholds for "sharing" personal information

The threshold change might seem like it reduces compliance obligations, but don't be fooled. The CPRA's expanded definition of "sharing" often brings more businesses into scope than the old "selling" definition.

Consumer Rights Expansion

The CPRA significantly expanded consumer rights beyond what CCPA originally provided:

New Rights Under CPRA:

  • Right to correct inaccurate personal information
  • Right to limit use of sensitive personal information
  • Enhanced right to opt-out (now covers "sharing" in addition to "selling")

I recently helped a client update their privacy policy to reflect these new rights, and we discovered they needed to completely restructure their data handling processes to accommodate correction requests.

Sensitive Personal Information Category

This is perhaps the biggest change. CPRA created an entirely new category called "sensitive personal information" (SPI) with special protections:

  • Social Security numbers and driver's license numbers
  • Account credentials and financial information
  • Precise geolocation data
  • Racial or ethnic origin, religious beliefs, political opinions
  • Health information and genetic data
  • Biometric information
  • Personal information about sex life or sexual orientation

Consumers can now limit how businesses use their SPI, which creates new compliance obligations you didn't have under the original CCPA.

New CPRA Requirements Your Business Must Address

Beyond the expanded consumer rights, CPRA introduced several new operational requirements that many businesses overlook:

Data Minimization and Purpose Limitation

CPRA explicitly requires businesses to:

  • Collect personal information only for disclosed, specific purposes
  • Not process personal information for undisclosed purposes
  • Minimize data collection to what's necessary for the disclosed purposes

This isn't just a policy requirement—it requires actual changes to your data collection practices. I've seen businesses struggle with this because their existing systems collected far more data than they actually needed.

Risk Assessment Obligations

For businesses processing significant amounts of personal information, CPRA requires regular risk assessments. You need to:

  • Identify and weigh privacy risks to consumers
  • Document your risk mitigation measures
  • Review and update assessments regularly

Enhanced Data Protection Requirements

CPRA strengthened security obligations, requiring businesses to implement "reasonable security procedures" that are more specifically defined than under the original CCPA.

Sensitive Personal Information: CPRA's Expanded Protections

The sensitive personal information provisions are where CPRA really shows its teeth. Here's what you need to understand:

The "Limit" Right vs. The "Opt-Out" Right

Under CCPA, consumers could opt-out of the "sale" of their personal information. Under CPRA, consumers can:

  • Opt-out of both "selling" and "sharing" of personal information
  • Limit the use and disclosure of sensitive personal information

The "limit" right for SPI is different from an opt-out. When a consumer exercises this right, you can still use their SPI for specific permitted purposes like:

  • Performing services reasonably expected by the consumer
  • Ensuring security and integrity
  • Short-term, transient use
  • Performing services on behalf of the business

But you cannot use SPI for other purposes like creating consumer profiles or targeted advertising.

Implementing SPI Controls

From a practical standpoint, implementing SPI controls requires:

  1. Data Classification: Identify what SPI you collect and process
  2. System Updates: Modify your systems to flag and handle SPI differently
  3. Process Changes: Update your procedures for SPI processing
  4. Consumer Interface: Provide clear options for consumers to limit SPI use

I worked with an e-commerce client who discovered they were collecting precise geolocation data through their mobile app without realizing it qualified as SPI under CPRA. We had to completely redesign their location services to comply with the new requirements.

Risk Assessment and Data Minimization Under CPRA

CPRA's risk assessment requirements aren't just paperwork exercises—they're meant to drive real changes in how you handle personal information.

When Risk Assessments Are Required

You need to conduct risk assessments if you:

  • Process personal information of 100,000+ consumers annually
  • Derive 50%+ of revenue from selling or sharing personal information
  • Process sensitive personal information of 100,000+ consumers annually

What Your Risk Assessment Must Cover

Your assessment should evaluate:

  • Whether your processing is necessary and proportionate
  • How you're minimizing privacy risks to consumers
  • Whether you have adequate safeguards in place
  • The effectiveness of your current privacy practices

Data Minimization in Practice

Data minimization under CPRA means you need to:

  • Collect only the personal information necessary for your disclosed purposes
  • Retain personal information only as long as necessary
  • Delete or de-identify information when it's no longer needed

This often requires significant changes to existing data retention policies and technical systems.

Compliance Deadlines and Implementation Timeline

Understanding CPRA's timeline is crucial for compliance:

January 1, 2022: CPRA's data collection requirements began (important for the 12-month lookback period)

January 1, 2023: Full CPRA enforcement began

July 1, 2023: California Privacy Protection Agency (CPPA) enforcement authority became effective

Ongoing: Risk assessments must be conducted regularly (CPRA doesn't specify frequency, but annually is generally recommended)

The key lesson I've learned from helping businesses through this transition: don't wait for deadlines. The businesses that started their CPRA compliance efforts early had much better outcomes than those who scrambled at the last minute.

How to Update Your Privacy Documentation for CPRA

Your CCPA-compliant privacy policy likely needs significant updates for CPRA. Here's what to focus on:

Required Policy Updates

Consumer Rights Section: Add the new rights (correction, limit use of SPI)

Data Categories: Clearly identify sensitive personal information

Processing Purposes: Be more specific about why you collect each type of data

Retention Periods: Include specific retention timelines where possible

Third-Party Sharing: Distinguish between "selling" and "sharing"

Notice at Collection Updates

Your collection notices need to be more detailed under CPRA:

  • Specific categories of SPI collected
  • Specific business purposes for each category
  • Whether SPI will be used for purposes other than those disclosed
  • Retention periods for each category of personal information

Consumer Request Mechanisms

You need to provide clear, accessible ways for consumers to:

  • Request correction of inaccurate information
  • Limit use of their sensitive personal information
  • Opt-out of sharing (in addition to selling)

The technical implementation of these request mechanisms often requires significant development work, especially for the correction right.

Common CPRA Compliance Mistakes to Avoid

After helping dozens of businesses navigate CPRA compliance, I've seen the same mistakes repeatedly:

Mistake 1: Treating CPRA as a Minor CCPA Update

CPRA isn't just CCPA with a few tweaks—it's a fundamental expansion of California privacy law. Businesses that approach it as a minor update often miss critical requirements.

Mistake 2: Ignoring the Sensitive Personal Information Requirements

Many businesses focus on the expanded consumer rights but overlook the SPI requirements. This is particularly problematic because SPI violations can trigger significant penalties.

Mistake 3: Inadequate Data Mapping

CPRA's data minimization and purpose limitation requirements demand detailed understanding of your data flows. Generic data mapping exercises often aren't sufficient.

Mistake 4: Delayed Implementation of Consumer Request Processes

The new consumer rights (especially correction and SPI limitation) require new technical capabilities. Many businesses underestimate the development time required.

Mistake 5: Overlooking Third-Party Relationships

CPRA's expanded definition of "sharing" often captures data flows that weren't considered "sales" under CCPA. This requires reviewing and potentially renegotiating vendor contracts.

Moving Forward: Your CPRA Compliance Action Plan

Based on my experience helping businesses achieve CPRA compliance, here's your practical next-step framework:

Immediate Actions (Next 30 Days):

  1. Conduct a gap analysis between your current CCPA compliance and CPRA requirements
  2. Inventory your sensitive personal information collection and processing
  3. Review your current privacy policy against CPRA requirements

Short-Term Actions (Next 90 Days):

  1. Update your privacy documentation to reflect CPRA requirements
  2. Implement consumer request processes for new rights
  3. Begin risk assessment procedures if you meet the thresholds

Ongoing Actions:

  1. Regular risk assessments and data minimization reviews
  2. Continuous monitoring of CPPA guidance and enforcement actions
  3. Periodic audits of third-party data sharing arrangements

The reality is that CPRA compliance isn't a one-time project—it's an ongoing business practice that requires continuous attention and regular updates.

Remember, California's privacy law landscape continues to evolve. The CPPA regularly issues new guidance, and enforcement actions provide additional clarity on compliance expectations. Staying compliant means staying informed and maintaining flexible systems that can adapt to regulatory changes.

The businesses that thrive under CPRA are those that view privacy compliance not as a burden, but as a competitive advantage and a way to build stronger relationships with their customers.

Ready to ensure your California privacy compliance is bulletproof? PrivacyForge's AI-powered platform generates comprehensive, CPRA-compliant privacy documentation tailored to your specific business practices. Stop worrying about whether you've covered all the requirements—let our technology handle the complexity while you focus on growing your business.