GDPR
EU regulation for personal data protection and privacy
CCPA
California regulation for consumer data privacy rights
Quick Verdict
GDPR mandates comprehensive data protection globally with strict consent and rights, while CCPA empowers California consumers via opt-out rights. Companies adopt GDPR for EU compliance and worldwide standards; CCPA to avoid CA fines and build US trust.
GDPR
Regulation (EU) 2016/679 - General Data Protection Regulation
Key Features
- Extraterritorial scope targeting non-EU entities serving EU residents
- Accountability principle requiring demonstrable compliance proof
- Fines up to 4% of global annual turnover for violations
- Data subject rights including erasure and portability
- 72-hour mandatory data breach notification requirement
CCPA
California Consumer Privacy Act (CCPA)
Key Features
- Right to know and access personal information collected
- Right to delete personal information from systems
- Opt-out of data sales and sharing via GPC links
- Right to correct inaccurate personal information
- Limit use of sensitive personal information
Detailed Analysis
A comprehensive look at the specific requirements, scope, and impact of each standard.
GDPR Details
What It Is
Regulation (EU) 2016/679, known as the General Data Protection Regulation (GDPR), is a directly applicable EU law enacted in 2016 and enforceable since May 25, 2018. It protects natural persons' rights regarding personal data processing, replacing the 1995 Data Protection Directive. Its risk-based, accountability-driven approach applies extraterritorially to any entity targeting EU data subjects.
Key Components
- Seven core principles: lawfulness, fairness, purpose limitation, data minimization, accuracy, storage limitation, integrity/confidentiality, and accountability.
- Enhanced data subject rights: access, rectification, erasure (right to be forgotten), restriction, portability, objection.
- Obligations like Data Protection Officers (DPOs), Data Protection Impact Assessments (DPIAs), Records of Processing Activities (ROPAs), 72-hour breach notifications.
- Enforcement via fines up to €20M or 4% global turnover; one-stop-shop for cross-border cases.
Why Organizations Use It
Mandatory for EU data processors; reduces legal risks, fines, reputational damage. Builds trust, enables global data flows via adequacy decisions, inspires worldwide standards like LGPD, CCPA. Enhances compliance culture, innovation balance.
Implementation Overview
Involves gap analysis, policy updates, training, DPO appointment, DPIAs, vendor contracts. Applies to all sizes processing EU data; no certification but ongoing audits by DPAs. Transition took 2 years; SMEs face high burdens.
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 applies to for-profit businesses meeting thresholds like $25M revenue or handling data of 100,000+ consumers. Its risk-based approach mandates notices, rights fulfillment, and security.
Key Components
- Consumer rights: know, delete, opt-out of sales/sharing, correct, limit sensitive data use.
- Obligations: privacy notices, data mapping, vendor contracts, DSAR handling within 45 days.
- Built on broad personal information definition, including inferences and devices; no fixed controls but "reasonable" practices.
- Compliance via self-attestation, CPPA enforcement.
Why Organizations Use It
- Legal compliance avoids fines up to $7,500/violation and breach litigation ($100-$750/consumer).
- Enhances trust, data governance efficiency, market differentiation.
- Risk mitigation, GDPR alignment for global ops.
Implementation Overview
Phased: scoping/gap analysis (0-3 months), policies/contracts (1-4 months), technical controls (2-6 months), ongoing operations/audits. Targets data-heavy industries; all sizes meeting thresholds; no certification but audits essential. (178 words)
Key Differences
| Aspect | GDPR | CCPA |
|---|---|---|
| Scope | Personal data processing worldwide | California residents' personal info |
| Industry | All industries, global reach | All for-profit businesses in CA |
| Nature | Mandatory EU regulation | Mandatory CA state law |
| Testing | DPIAs for high-risk processing | Reasonable security measures |
| Penalties | Up to 4% global turnover | $2,500-$7,500 per violation |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about GDPR and CCPA
GDPR FAQ
CCPA FAQ
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