CCPA
California regulation for consumer personal data rights
GDPR UK
UK regulation for personal data protection and privacy.
Quick Verdict
CCPA grants California consumers rights to know, delete, and opt-out of personal data sales for qualifying businesses, while GDPR UK mandates comprehensive data protection principles and rights for all UK data processors. Organizations adopt CCPA for CA compliance and GDPR UK for broad UK accountability.
CCPA
California Consumer Privacy Act (CCPA/CPRA)
Key Features
- Grants consumers rights to know, delete, opt-out, correct data
- Applies to businesses with $25M revenue or 100K CA consumers
- Mandates GPC honoring and Do Not Sell/Share links
- Requires notices at collection and privacy policies
- Imposes $7,500 per violation fines and breach actions
GDPR UK
UK General Data Protection Regulation (UK GDPR)
Key Features
- Seven core data processing principles
- Data subject rights including erasure and portability
- Accountability requiring demonstrable compliance evidence
- Mandatory DPIAs for high-risk processing
- 72-hour ICO breach notification requirement
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), amended by the California Privacy Rights Act (CPRA), is a state regulation granting California residents rights over personal information handled by businesses. Its purpose is to enhance consumer control, transparency, and security in data processing. Scope targets for-profits meeting thresholds like $25M revenue or 100K consumers' data. It uses a rights-based approach with risk-proportionate obligations.
Key Components
- Core rights: know/access, delete, opt-out sales/sharing, correct, limit sensitive PI
- Obligations: notices at collection, privacy policies, 45-day request responses, vendor contracts
- Principles: data minimization, reasonable security, non-discrimination
- No certification; compliance demonstrated via documentation and audits
Why Organizations Use It
- Mandatory for qualifiers to avoid $2,500-$7,500 per violation fines by CPPA/AG
- Private right of action for breaches reduces litigation risk
- Builds trust, differentiates in market, improves governance efficiency
- Enables partnerships, aligns with GDPR-like regimes
Implementation Overview
- Phased: scoping (0-3 months), policies/contracts (1-4), technical controls (2-6), operationalize/audit
- Applies globally to CA data handlers, all sizes meeting thresholds
- Cross-functional: legal, IT, security; automate DSARs/opt-outs
- Ongoing: training, metrics, regulatory monitoring (178 words)
GDPR UK Details
What It Is
UK GDPR (UK General Data Protection Regulation) is the UK's post-Brexit adaptation of the EU GDPR, a binding legal regulation enforced by the ICO. It governs personal data processing with a risk-based, accountability-focused approach, applying to UK-established organizations and those targeting UK individuals extraterritorially.
Key Components
- Seven core principles: lawfulness, purpose limitation, minimisation, accuracy, storage limitation, security, accountability.
- Data subject rights (access, rectification, erasure, portability, objection).
- Controller/processor obligations (RoPAs, contracts, DPIAs, breaches).
- No fixed controls; compliance via demonstrable governance, with fines up to 4% global turnover.
Why Organizations Use It
- Mandatory for legal compliance to avoid ICO fines (£17.5M max).
- Manages data risks, builds trust, enables secure innovation.
- Enhances reputation, operational efficiency, vendor assurance.
Implementation Overview
Phased: gap analysis, RoPA mapping, policies, training, DPIAs, audits. Applies to all sizes processing UK data; no certification, but ICO audits/enforcement.
Key Differences
| Aspect | CCPA | GDPR UK |
|---|---|---|
| Scope | Consumer rights over personal info sales/sharing | Comprehensive data protection principles/rights |
| Industry | For-profit businesses meeting CA thresholds | All organizations processing UK personal data |
| Nature | CA state consumer privacy regulation | UK-wide mandatory data protection regulation |
| Testing | No mandatory audits; reasonable security practices | DPIAs for high-risk; regular security testing |
| Penalties | $2,500-$7,500 per violation; breach private actions | Up to £17.5M or 4% global turnover |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about CCPA and GDPR UK
CCPA FAQ
GDPR UK FAQ
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