CPRA Compliance Checklist

I. Compliance Program Overview

Objective: To ensure [YOUR COMPANY NAME] complies with the California Privacy Rights Act (CPRA) and other relevant privacy regulations.

Compliance Officer: [YOUR NAME], [YOUR TITLE]

Effective Date: [DATE]

Review Schedule: Bi-annually or as required by changes in CPRA or other applicable laws.

Review existing privacy policies to comply with CPRA requirements.
Assign a compliance officer to oversee CPRA compliance.
Establish a clear timeline for implementing CPRA compliance measures.
Regularly review and update CPRA compliance efforts as needed.

II. Data Processing Policies

Data Collection and Use

Review and update data processing policies to align with CPRA requirements.
Implement procedures for obtaining consent for data processing activities.
Establish protocols for responding to data subject requests under CPRA.
Develop procedures for documenting and tracking data processing activities.

Data Retention and Deletion

Conduct a data inventory to identify gathered personal information.
Implement appropriate data retention policies and procedures.
Set up secure methods to delete or anonymize personal data when requested.
Train employees on proper data retention and deletion procedures.

III. Data Protection Measures

Data Security

Safeguard personal information from unauthorized actions.
Regularly conduct security checks to identify and handle vulnerabilities.
Ensure vendors follow CPRA-mandated data security standards.
Provide ongoing training to employees on data security best practices.

Data Minimization

Minimize unnecessary personal data collection by reviewing practices.
Limit access to personal information to authorized personnel only.
Regularly refresh vendor deals for data minimization compliance.
Implement automated data minimization measures where feasible.

IV. Privacy Notices and Disclosures

Include CPRA-required details in revised privacy notices/disclosures.
Detail clear data processing including reasons, types of collected personal info, and consumer rights.
Ensure transparency regarding the sale and sharing of personal information and provide opt-out mechanisms as required by CPRA.
Train customer service representatives on how to properly respond to consumer inquiries about privacy notices and disclosures.

V. Employee Training and Awareness

CPRA Training

Train employees thoroughly on CPRA requirements and responsibilities.
Regularly train employees on CPRA regulation updates.
Provide training manuals and online modules for CPRA training.
Monitor employee participation and completion of CPRA training activities.

Privacy Awareness

Promote personal information best practices to cultivate privacy awareness culture.
Urge employees to report observed privacy issues or violations.
Reward employees for excellent privacy practices.
Include privacy awareness in employee evaluations and goal-setting.

VI. Vendor Management

Vendor Assessment

Oversee vendor and third-party personal information handling compliance.
Make sure vendor contracts have CPRA compliance and data protection clauses.
Regularly check vendor practices for CPRA compliance.
Set up procedures to end vendor contracts if they don't comply with CPRA.

Vendor Communication

Inform vendors and third parties about CPRA compliance expectations.
Train vendors on CPRA requirements or provide relevant resources.
Set up ongoing communication and collaboration channels with vendors for CPRA compliance.
Record all vendor communications about CPRA compliance.

VII. Data Breach Response Plan

Plan Development

Develop a CPRA-compliant data breach response plan.
Determine main stakeholders, define their roles and duties during a data breach.
Set up protocols to evaluate data breach severity and decide proper responses.
Conduct tabletop exercises and simulations to test the effectiveness of the data breach response plan.

Incident Response

Establish procedures for promptly responding to data breach incidents.
Develop templates for notifying affected individuals and regulatory authorities in the event of a data breach.
Establish a communication plan for keeping internal and external stakeholders informed during a data breach incident.
Document all steps taken in response to data breach incidents for post-incident analysis and reporting.

VIII. Record-keeping and Documentation

Record Maintenance

Maintain records of data processing activities, including data subject requests, consents, and data breaches.
Ensure records are organized, secure, and easily accessible for auditing purposes.
Implement a document retention policy to ensure records are retained for the required duration.
Regularly review and update records to ensure accuracy and completeness.

Documentation

Document all incidents, breaches, or complaints related to CPRA compliance.
Maintain comprehensive CPRA compliance records such as policy alterations, trainings, and audits.
Maintain a central storage for quick CPRA document reference and retrieval.
Apply version control for tracking changes in CPRA-related documents.

IX. Signature

This CPRA Compliance Checklist Template is designed to assist [YOUR COMPANY NAME] in ensuring compliance with the California Privacy Rights Act. Please customize the checklist according to your organization's specific requirements and practices.

[YOUR NAME]