This article explains how businesses can structure their CCPA program around ten operational steps, from data mapping and privacy policies to opt-out links, consumer request handling, data minimization, and retention. It also describes how Clym’s tools can support these activities through consent management, policy management, request workflows, scanning, and governance features.
The California Consumer Privacy Act (CCPA), strengthened by the California Privacy Rights Act (CPRA), continues to shape how businesses manage personal information in 2026. Organizations working with California residents’ information need clear procedures for collecting data, managing requests, and providing transparent notices. Two topics consistently appear as operational priorities: structured compliance steps and the role of data minimization.
This article provides a structured checklist that reflects key operational elements expected under the CCPA and CPRA, as well as the obligations outlined in the official CCPA Regulations issued by the California Privacy Protection Agency. It covers data mapping, transparent privacy notices, opt-out mechanisms, data minimization practices, and consumer request handling, all supported by internal governance and ongoing reviews. It also outlines how Clym’s tools can support these operational steps in a practical and organized way.
While this checklist focuses on the operational steps you need to take right now, you can explore the full legal framework and every expanded consumer right in our comprehensive CCPA compliance guide 2026.
A complete data inventory forms the foundation of any CCPA privacy program. Businesses need to understand:
A detailed data map supports privacy policies, Notices at Collection, consumer request responses, and opt-out disclosures. Platforms like Clym can assist by offering website scanning that highlights data collection points and third-party tools involved.
To provide clarity for consumers, it is important to distinguish between the Privacy Policy and the Notice at Collection. Under the CCPA/CPRA, these are separate disclosures with different purposes and requirements. The Privacy Policy is the primary, public-facing transparency document, while the Notice at Collection must be provided at or before the point of data collection.
A smooth and accurate disclosure experience begins with keeping both documents aligned. This step focuses on reviewing and updating the Privacy Policy and the Notice at Collection so they consistently reflect how personal information is collected and used.
Requirement | Privacy Policy (legally required) | Notice at Collection (legally required) |
|---|---|---|
Categories of personal information | Describes categories collected across operations | Lists categories collected at the point of collection |
Purposes for each category | Explains purposes for each category | States purposes for each category |
Sale or sharing of data | Discloses whether personal information is sold or shared and links to opt-out | States if personal information collected at that moment is sold or shared |
Consumer rights | Outlines rights to know, delete, correct, and opt out | Not required to list full rights |
Request submission methods | Provides at least two methods for submitting requests | May link to the Privacy Policy or a DSR form |
Retention periods | Describes retention criteria | Discloses retention periods or specific criteria |
Sensitive personal information | Describes use and right to limit | States if sensitive personal information is collected at that point |
Both disclosures support transparency, but they play different roles. The Privacy Policy explains overall practices, while the Notice at Collection provides real-time transparency whenever data is collected. Keeping them aligned helps consumers understand what is collected and why, and helps businesses maintain accurate disclosures across all data touchpoints.
The Privacy Policy is the primary transparency obligation under the CCPA/CPRA. It explains what personal information the business collects, why it is collected, how it is used, whether it is sold or shared, and how consumers can exercise their rights. It also reflects retention criteria (the specific periods appear in the Notice at Collection), sensitive personal information practices, and findings from the data inventory. Because it ties directly to every operational area of the CCPA, it benefits from regular reviews and updates as business practices evolve.
If your website uses cookies that may constitute selling or sharing under CCPA, your banner may support presenting choices, but the law requires the opt-out mechanism itself, not a banner, and a link back to the disclosures in both the Privacy Policy and the Notice at Collection.
California residents must be able to opt out of:
A visible, functional opt-out link is required in the header or footer of the website, as well as any relevant pages. Consent and preference tools such as those offered by Clym support businesses in presenting these options clearly, including adding a footer link for “Do Not Sell or Share My Personal Information.” Businesses should also treat valid Global Privacy Control (GPC) signals as opt-out requests.
Businesses need to support:
Operational steps include:
Data minimization is a core CPRA principle and now part of CCPA enforcement expectations. It means:
Purpose limitation supports this by requiring businesses to explain and document the reasoning for all data uses. Minimization also supports lower risk exposure and helps with operational simplicity when managing consumer requests.
To support practical application of CCPA data minimization requirements and CPRA storage limitation rules, the table below illustrates common bad practices versus better practices that align with collecting and retaining only what is reasonably necessary.
Bad practice (what to avoid) | Better practice (supports minimization & storage limitation) |
|---|---|
Collecting full date of birth for an email newsletter signup | Collecting only email address and first name for newsletter delivery |
Requiring phone numbers for downloadable PDFs or whitepapers | Offering downloads in exchange for email only |
Requesting home address for general account creation | Requesting address only at checkout for shipping purposes |
Storing inactive user accounts indefinitely | Deleting or anonymizing accounts after a defined retention period |
Collecting extensive demographic data (age, gender, ethnicity) for basic website access | Collecting only essential operational information based on disclosed purposes |
Using one form to collect every possible field “just in case” | Tailoring forms so each field matches the stated purpose in the Notice at Collection |
These examples help illustrate how data minimization and storage limitation work in practice under the CCPA/CPRA. They also help businesses evaluate whether the personal information they collect aligns with what is necessary for the disclosed purpose. CCPA data minimization requirements increasingly influence enforcement expectations, while CPRA storage limitation strengthens the need for clear retention policies tied to those purposes.
CPRA requires organizations to:
This step directly reinforces minimization by preventing open-ended data storage.
When a business shares personal information with service providers, contracts must include:
These contracts also help clarify which disclosures qualify as “sharing” under CCPA.
Teams handling personal information or consumer requests need ongoing training. Training topics typically include:
A well-informed team is essential for consistent privacy operations.
Compliance efforts require ongoing attention. Businesses benefit from:
This prevents outdated disclosures and reduces inconsistencies across digital properties.
Many organizations encounter:
Addressing these challenges typically involves internal coordination, clear governance, and consistent workflows. Businesses may also find it helpful to run periodic scans using tools such as the Clym Scanner to identify new scripts or trackers that could affect their obligations.
Clym provides tools that support businesses as they build and maintain CCPA practices, including:
Businesses benefit from organizing their CCPA efforts around a repeatable structure: clear data mapping, accurate privacy disclosures, accessible opt-out tools, efficient request handling, documented data minimization and retention rules, and ongoing website and vendor reviews. Platforms like Clym can support these operational needs.
This consolidated guide brings together actionable steps and core principles such as data mapping, transparent notices, opt-out options, consumer rights, and data minimization. Revisiting these areas regularly helps businesses maintain a structured approach that supports California’s privacy requirements in 2026.
Yes. The CCPA applies to organizations located outside California if they collect personal information from California residents and meet certain thresholds related to revenue, data volume, or data selling or sharing practices.
The CCPA generally applies to businesses that meet at least one of the following criteria:
The CCPA applies to a broad range of personal information, including identifiers, commercial information, internet activity, geolocation data, employment details, and inferences drawn from these categories.
Yes. The privacy policy is the primary public-facing document that summarizes an organization’s data practices across all operations. The privacy notice is provided at or before the point of collection and focuses on the specific information gathered in that moment.
If a business sells personal data or shares it for cross-context behavioral advertising, it must offer a visible opt-out mechanism.
Yes. Businesses must verify identity before responding to access, deletion, or correction requests.
Businesses generally have 45 days to respond, with a possible 45-day extension.
No. Businesses cannot charge consumers for exercising their rights.
Yes. Cookies and other tracking technologies can constitute selling or sharing personal information depending on how data is used.
Sensitive personal information includes categories like precise geolocation, financial data, and health information. CPRA introduced a right for consumers to limit certain uses.
The CCPA expects privacy policies to be reviewed and updated regularly—typically annually or whenever practices change.
Failure to respond may lead to enforcement action and administrative penalties.
Businesses must obtain opt-in consent for selling or sharing personal information of minors under 16. For minors under 13, a parent or guardian must provide consent.
The CPPA is responsible for enforcing CCPA and CPRA requirements, issuing regulations, and conducting audits.
Alex is a Content Developer at Clym, where he researches and writes about everything related to data privacy and web accessibility compliance for businesses, helping them stay informed on their compliance needs and spreading awareness about making the web safer and more inclusive. When he’s not writing about compliance, Alex has his nose in a book or is hiking in the great outdoors.
Find out more about Alex