Our data privacy and compliance experts translate the technical into practical and cut through less-than-specific legal requirements to navigate the complex compliance with the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA).
Organizations subject to the CCPA must evaluate their compliance with an increasing set of regulations designed to give consumers more control over their personal information. The CCPA, strengthened by CPRA passed in November, secures new privacy rights, audit obligations and mandates reasonable cyber security measures. To evaluate your organization’s CCPA exposure, Kroll experts can assess your organization’s current privacy and cyber security posture and build a roadmap to becoming compliant.
Initial CCPA Gap Analysis
Our experts will assess your organization’s current compliance with CCPA through a review of existing policies and controls using a cloud-based questionnaire that facilitates collaboration. The analysis identifies the relevant clauses of the statute and explains those clauses in plain English. Stakeholders from your organization, including privacy and compliance officers, information security leaders and legal counsel, can be assigned specific questions and our team will help with the completion of the questionnaire.
The initial assessment will identify gaps and provide recommendations against:
- Adequate provision of notices regarding the collection of personal info (PI)
- How the collection of PI is conducted and whether it matches the privacy notice
- Assessing the value of the PI collected and documenting the method used for such calculation
- Ability to manage requests such as:
- Right to know
- Right to delete
- Right to opt out of third-party sales and sharing
- Right to nondiscrimination
- Right to correction
- Right to data portability
- Sharing of PI for behavioral advertising
- Scope of collection and retention of PI are reasonable and documented
Business Unit and/or Vendor Assessments for CCPA
It’s important to recognize that CCPA compliance is a gradual process that may be more efficiently approached in phases, depending on the size and structure of the organization. The flexibility of our cloud-based assessment questionnaire allows organizations to examine specific business units, regions or vendors and how they’re complying with CCPA requirements from a central location. Tracking first and third-party compliance from a single dashboard gives your privacy office greater visibility and helps identify areas of focus, maximizing the impact of your efforts.
CCPA Risk Assessment Through CIS Controls™
The CCPA requires all organizations to implement reasonable security measures to protect personal information. Our experts will conduct a cyber security program assessment using the Center for Internet Security (CIS) Top 20 Controls, which have been adopted by the state of California, to evaluate your organization’s security controls and processes. The assessment includes:
- Basic controls – including inventory and control of hardware and software assets, administrative privilege management, continuous vulnerability management, and the maintenance and monitoring of audit logs
- Foundational controls – including email and browser protections, malware and boundary defense, limitations over network ports and protocols, data recovery capabilities, wireless access control, and account monitoring
- Organizational controls – including security awareness and training programs, application software security, incident response management, and penetration tests
Data Mapping and Inventory Exercise
The CCPA grants California consumers the right to know what personal information is being collected, used, shared or sold. To properly provide this information to clients, your organization must perform a thorough data inventory and update it on a frequent basis, mapping existing data flows and noting where data is transferred to, stored, and the security controls in place.
The data inventory exercise also helps identify third parties that may have access to PI, and our privacy and contract experts can then help review agreements to identify potential exposure, such as the inability to audit in the event of a cyber security incident.
Watch Jonathan Fairtlough, Managing Director in Kroll’s Cyber Risk practice, discuss the importance of a data inventory: