CCPA
California regulation for consumer personal data privacy rights
APRA CPS 234
Australian prudential standard for information security resilience
Quick Verdict
CCPA grants California consumers privacy rights like know, delete, opt-out, while APRA CPS 234 mandates financial firms' information security governance, testing, and incident reporting. Companies adopt CCPA for compliance and trust, CPS 234 for regulatory resilience.
CCPA
California Consumer Privacy Act (CCPA/CPRA)
Key Features
- Grants consumers rights to know, delete, opt-out, correct data
- Requires notices at collection and Do Not Sell/Share links
- Applies to businesses with $25M revenue or 100K CA consumers
- Mandates Global Privacy Control signal honoring for opt-outs
- Imposes $2,500-$7,500 fines per violation plus breach actions
APRA CPS 234
APRA Prudential Standard CPS 234 Information Security
Key Features
- Board ultimate responsibility for information security
- 72-hour APRA notification for material incidents
- Third-party assets fully in scope with assessments
- Systematic risk-based control testing program
- Internal audit assurance including third parties
Detailed Analysis
A comprehensive look at the specific requirements, scope, and impact of each standard.
CCPA Details
What It Is
The California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), is a state regulation establishing consumer privacy rights for California residents. It targets for-profit businesses meeting thresholds like $25M revenue or handling 100K+ consumers' data. Primary purpose: empower consumers over personal information via rights-based approach with risk-tiered obligations.
Key Components
- Core consumer rights: know/access, delete, opt-out sale/share, correct, limit sensitive PI use
- Notices at collection, privacy policies, Do Not Sell/Share links, GPC honoring
- Business obligations: data mapping, vendor contracts, security measures, DSAR handling within 45 days
- Enforcement by CPPA and AG with per-violation fines
Why Organizations Use It
Mandatory for qualifying businesses to avoid $7,500/violation fines and breach litigation. Drives data governance efficiency, builds consumer trust, enables market differentiation, aligns with GDPR-like regimes, reduces breach risks.
Implementation Overview
Phased: scoping/gap analysis (0-3 months), policies/contracts (1-4 months), technical controls (2-6 months), operationalization/training, ongoing audits. Applies globally to CA-linked data handlers; no certification but demonstrable compliance via audits.
APRA CPS 234 Details
What It Is
APRA Prudential Standard CPS 234 (Information Security) is a binding regulation for APRA-regulated financial institutions in Australia. Effective 1 July 2019, it mandates information security capabilities commensurate with threats and vulnerabilities to minimize incidents impacting confidentiality, integrity, or availability (CIA) of information assets, including those managed by third parties. It adopts a risk-based, assurance-driven approach with board accountability.
Key Components
- Board ultimate responsibility and defined roles (paras 13-14)
- Asset classification by criticality and sensitivity (para 20)
- Commensurate controls across asset lifecycle (para 21)
- Systematic testing and independent assurance (paras 27-34)
- Incident response plans with annual testing (paras 23-26)
- APRA notifications: 72 hours for material incidents, 10 business days for control weaknesses (paras 35-36) No fixed controls; focuses on outcomes and testing.
Why Organizations Use It
Mandatory for banks, insurers, super funds; ensures prudential stability, reduces cyber risks, builds resilience. Drives vendor oversight, regulatory compliance, customer trust, and operational continuity.
Implementation Overview
Phased: gap analysis, governance/policies, asset inventory/classification, controls/testing, third-party assessments. Applies Australia-wide to regulated entities of all sizes; ongoing internal audit, no certification but APRA enforcement.
Key Differences
| Aspect | CCPA | APRA CPS 234 |
|---|---|---|
| Scope | Consumer privacy rights and data handling | Information security governance and cyber resilience |
| Industry | All businesses meeting CA thresholds, global reach | Australian financial services (banks, insurers, super) |
| Nature | Mandatory state privacy regulation with fines | Mandatory prudential standard with supervisory actions |
| Testing | Reasonable security practices, no mandated testing | Systematic independent testing, annual reviews required |
| Penalties | $2,500-$7,500 per violation, private breach actions | Regulatory directions, remediation, potential license risks |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about CCPA and APRA CPS 234
CCPA FAQ
APRA CPS 234 FAQ
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