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To comply with the California Consumer Privacy Act (CCPA), first determine whether your business meets a coverage threshold, then align your data inventory, notices, consumer-request process, opt-out controls, vendors, and security practices with the law. California’s 2026 guidance also makes current CPPA regulations and the DROP data-broker deletion system relevant to ongoing compliance. The steps below are a practical starting point, not legal advice; unusual exemptions, children’s information, sensitive data, automated decision-making, or enforcement issues warrant advice from qualified counsel.
1. Determine whether the CCPA covers your business
The CCPA generally covers for-profit businesses doing business in California if they meet at least one of these thresholds. The California Department of Justice’s 2026 guidance describes the thresholds as:
- More than $25 million in gross annual revenue.
- Buying, selling, or sharing the personal information of 100,000 or more California residents or households.
- Deriving at least 50% of annual revenue from selling California residents’ personal information.
Nonprofits and government agencies generally are not covered. Do not assume that serving Californians alone settles the question: assess your business structure, California activities, revenue, and data practices against the applicable rules. If an exemption or the way a threshold applies to your business is unclear, get legal advice before deciding that the law does not apply.
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Build an inventory that follows information from collection through use, sharing, retention, and deletion. Record the collection point, category of information, purpose, source, recipients, whether it is sold or shared, the service providers or contractors involved, retention practice, and the systems or locations where it can be deleted. Include websites, apps, customer support, marketing, and other relevant operations rather than limiting the inventory to one database.
Identify sensitive personal information
California’s sensitive-personal-information categories include government identifiers; account credentials; precise geolocation; private communications; genetic and biometric data; health information; sexual orientation; race or ethnicity; religious or philosophical beliefs; and union membership. Mark these categories separately in the inventory so you can identify where the right to limit use and disclosure may apply.
3. Make notices match actual practices
Give consumers a notice at or before collection that describes the categories of personal information collected and the purposes for which it will be used. Maintain a privacy policy that explains the business’s practices and how consumers can exercise their rights. The inventory from step 2 should inform both documents: a notice or policy that describes different data or purposes can mislead consumers and make it harder to fulfill requests correctly.
If the business sells or shares personal information, provide a clear “Do Not Sell or Share My Personal Information” mechanism. Make sure the notice and mechanism accurately reflect the business’s current practices, and update them when those practices change.
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Set up a process to receive, route, verify when required, fulfill, and record requests to know, delete, correct, opt out of sale or sharing, and limit the use of sensitive personal information. Define who owns each request type and how staff will find relevant information across the systems in the data inventory. Keep records of the request, verification method where applicable, actions taken, and response.
Use the right verification approach
Document reasonable identity-verification methods for requests that require verification. Do not apply the same verification gate to every request: California’s rules prohibit requiring identity verification for opt-out or limit requests in circumstances where verification is not allowed.
Track statutory response windows
| Request type | Response window | What to plan for |
|---|---|---|
| Opt out of sale or sharing | As soon as feasible, and no later than 15 business days | California Department of Justice 2026 guidance sets the maximum at 15 business days. |
| Delete | Generally within 45 calendar days; a further 45 days may be available after notice | California Department of Justice 2026 guidance describes the possible extension, allowing up to 90 calendar days in total when properly extended. |
Use separate tracking for business days and calendar days so an operational queue does not confuse the two clocks. The extension is not an automatic extra period: give notice when relying on it.
5. Honor opt-outs, Global Privacy Control, and consumer choice
Treat a user-enabled Global Privacy Control (GPC) signal as an opt-out where applicable. Once an opt-out is received, do not sell or share that consumer’s personal information unless the consumer later authorizes it. The opt-out process must not require the consumer to create an account, and consumers must not be discriminated against for exercising CCPA rights.
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Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.6. Govern vendors, security, and higher-risk processing
Make sure service providers and contractors receive applicable deletion and opt-out instructions, and retain evidence of the responses. Review security controls alongside these data flows so that information remains protected wherever it is handled.
For 2026, assess whether the business is subject to CPPA requirements concerning risk assessments, annual cybersecurity audits, or automated decision-making. The California Privacy Protection Agency says those regulation updates became effective January 1, 2026. Applicability depends on the rules and the business’s processing; do not assume that every covered business has the same obligations.
Choose an implementation model against the work required
Whether work is handled in-house, with a compliance platform, or with outside counsel, compare the options against the same operational needs:
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- Coverage of know, delete, correct, opt-out, and limit workflows.
- Verification and deadline tracking.
- Support for notices and the data inventory.
- Vendor coordination and evidence management.
- Support for applicable 2026 risk-assessment, audit, and automated-decision-making requirements.
- Integration effort, staff expertise, and total cost.
These are evaluation criteria, not evidence that any particular tool or service guarantees compliance. Match the approach to the systems, expertise, and work your organization actually needs.
7. Keep the program current and account for DROP
Monitor updates from the California Privacy Protection Agency and Attorney General, and revise notices, workflows, and internal procedures when requirements or business practices change. California’s Attorney General described the Delete Request and Opt-out Platform (DROP) in a February 18, 2026 alert: consumers can use one request to reach more than 500 registered data brokers, and brokers were required to begin deleting through the system on August 1, 2026. That start date has passed; the alert does not establish that every broker has completed deletion. Where data-broker deletion is relevant, explain DROP to California residents and keep the business’s own applicable duties distinct from the obligations imposed on registered brokers.
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