CCPA
California regulation granting consumers data privacy rights
MAS TRM
Singapore guidelines for technology risk management in finance
Quick Verdict
CCPA grants California consumers privacy rights like opt-out and deletion, while MAS TRM mandates technology risk governance for Singapore FIs. Companies adopt CCPA to avoid fines and build trust; MAS TRM for regulatory compliance and cyber resilience.
CCPA
California Consumer Privacy Act (CCPA/CPRA)
Key Features
- Consumer rights to know, delete, opt-out of sales/sharing
- Broad personal information definition including inferences/households
- Threshold applicability: $25M revenue or 100K consumers/devices
- Fines up to $7,500 per intentional violation by CPPA/AG
- Private right of action for unencrypted data breaches
MAS TRM
MAS Technology Risk Management Guidelines
Key Features
- Board and senior management accountability
- Proportional risk-based implementation
- Comprehensive technology lifecycle controls
- Third-party risk management integration
- Annual penetration testing for internet systems
Detailed Analysis
A comprehensive look at the specific requirements, scope, and impact of each standard.
CCPA Details
What It Is
California Consumer Privacy Act (CCPA), as amended by California Privacy Rights Act (CPRA), is a state regulation establishing consumer privacy rights for California residents. It applies extraterritorially to for-profit businesses meeting thresholds like $25M revenue or handling 100K+ consumers' data. Primary purpose: empower consumers with control over personal information (PI) via rights-based approach including opt-out of sales/sharing.
Key Components
- Core consumer rights: know/access, delete, correct, opt-out sales/sharing, limit sensitive PI use
- Obligations: notices at collection, privacy policies, vendor contracts, data mapping
- Enforcement by CPPA and Attorney General with $2,500-$7,500 fines per violation
- Private action for breaches; no formal certification, but audits demonstrate reasonableness
Why Organizations Use It
Mandatory for qualifying businesses to avoid fines, litigation, reputational damage. Builds trust, enables market access, improves data governance/efficiency, aligns with GDPR-like regimes for competitive edge.
Implementation Overview
Phased: scoping/gap analysis (0-3 months), policies/contracts (1-4 months), technical controls (2-6 months), operationalization/training, ongoing audits. Targets large data handlers in tech/retail/finance; cross-functional teams essential.
MAS TRM Details
What It Is
MAS Technology Risk Management (TRM) Guidelines (January 2021) are supervisory guidelines issued by Singapore's Monetary Authority of Singapore (MAS) for financial institutions. They provide principles-based guidance on managing technology and cyber risks, emphasizing governance, controls, and resilience to protect confidentiality, integrity, and availability (CIA) of systems and data. The approach is risk-based and proportional to an FI's complexity and risk profile.
Key Components
- Covers 15 sections including governance, risk frameworks, secure development, IT service management, resilience, access controls, cryptography, cyber operations, assessments, and audit.
- Synthesizes into 12 core principles like board accountability, asset management, third-party oversight, and layered cyber defenses.
- No fixed controls; focuses on outcomes with continuous improvement.
- Compliance via supervisory review, not formal certification.
Why Organizations Use It
- Meets MAS supervisory expectations to avoid fines and enforcement.
- Enhances cyber resilience and operational stability.
- Builds trust with regulators, customers, and stakeholders.
- Enables secure digital transformation.
Implementation Overview
- Phased: governance setup, asset inventory, risk assessment, control deployment, testing.
- Applies to all MAS-supervised FIs; scalable by size.
- Requires board-approved strategies, independent assurance, no mandatory certification.
Key Differences
| Aspect | CCPA | MAS TRM |
|---|---|---|
| Scope | Consumer privacy rights, data sales/sharing | Technology/cyber risk governance, resilience |
| Industry | All businesses meeting CA thresholds | Singapore financial institutions only |
| Nature | Mandatory state privacy law | Supervisory guidelines, proportionate |
| Testing | Security audits for breach liability | Annual pen tests, vulnerability scans |
| Penalties | $2,500-$7,500 per violation, private suits | Supervisory fines, license actions |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about CCPA and MAS TRM
CCPA FAQ
MAS TRM FAQ
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