CCPA
California law granting residents rights over personal data
PDPA
Southeast Asia regulations for personal data protection
Quick Verdict
CCPA mandates California consumer rights like know/delete/opt-out for businesses meeting thresholds, while PDPA requires Singapore organizations to protect personal data via consent, security, DPO. Companies adopt CCPA for CA compliance, PDPA for SE Asia operations and trust.
CCPA
California Consumer Privacy Act (CCPA/CPRA)
Key Features
- Grants consumers rights to know, delete, correct personal data
- Requires opt-out of sales/sharing via GPC and links
- Applies to businesses over $25M revenue or 100K CA consumers
- Mandates notices at collection and detailed privacy policies
- Enforces fines up to $7,500 per violation plus breach actions
PDPA
Personal Data Protection Act (PDPA)
Key Features
- Mandatory breach notification within 72 hours
- Consent and lawful bases for processing
- Data Protection Officer appointment
- Cross-border transfer limitations and safeguards
- Data subject rights including access and correction
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 granting California residents rights over their personal information. It targets for-profit businesses meeting thresholds like $25M revenue or handling data of 100K+ consumers. Primary purpose: empower consumers with control via opt-out model, supported by notices and enforcement.
Key Components
- Consumer rights: know/access, delete, correct, opt-out sales/sharing, limit sensitive data
- Business obligations: data mapping, notices at collection, vendor contracts, GPC honoring
- Enforcement by CPPA and Attorney General with $2,500-$7,500 fines per violation
- Private right of action for breaches; no formal certification, compliance via audits
Why Organizations Use It
Mandatory for qualifying businesses to avoid fines, litigation, reputational harm. Builds trust, differentiates in market, improves data governance, enables partnerships, future-proofs against state laws.
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 data handlers; cross-functional teams essential.
PDPA Details
What It Is
PDPA (Personal Data Protection Act) refers to a family of data protection laws in jurisdictions like Singapore (2012), Thailand (2019), and Taiwan, primarily regulations governing organizations' collection, use, disclosure, and protection of personal data. These are principles-based frameworks balancing individual privacy rights with legitimate business needs, employing risk-based approaches with consent, exceptions, and accountability.
Key Components
- Core obligations: consent/notification, purpose limitation, data subject rights (access, correction), security safeguards, breach notification, cross-border transfers, accountability (including DPO in some regimes).
- Built on GDPR-influenced principles; no fixed control count but operational requirements like 72-hour breach reporting.
- Compliance via self-assessment, guidance adherence; enforcement by PDPCs with fines up to SGD/THB 1-5M.
Why Organizations Use It
Mandatory for entities processing local data; drives risk mitigation, trust-building, operational resilience. Enables market access, reduces fines/reputational harm, supports ethical data use in BFSI, healthcare, e-commerce.
Implementation Overview
Phased: governance, data mapping, policies, controls, training, audits. Applies to all sizes in covered geographies; no certification but PDPC guidance/DPIAs recommended. (178 words)
Key Differences
| Aspect | CCPA | PDPA |
|---|---|---|
| Scope | Consumer rights over personal info in CA | Personal data collection/use/disclosure by orgs |
| Industry | For-profits meeting CA thresholds, global reach | Private sector orgs in Singapore/SE Asia |
| Nature | Mandatory CA state regulation, fines/litigation | Mandatory principles-based act, PDPC enforcement |
| Testing | Internal audits, security assessments, no cert | DPMP audits, DPIAs, DPO oversight |
| Penalties | $2,500-$7,500/violation, private breach suits | Up to S$1M or 10% revenue, enforcement notices |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about CCPA and PDPA
CCPA FAQ
PDPA FAQ
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