Applying the Information Protection Life Cycle and Framework to CCPA

The California Consumer Privacy Act (CCPA) became effective on January 1, 2020. Enforcement is slated to start by July 1, 2020. CCPA is complex regulation which does bear some similarities with EU GDPR. For more information on how CCPA and GDPR compare, see our webinar. Both regulations deal with how organizations handle PII (Personally Identifiable Information). CCPA intends to empower consumers to give them a choice to disallow onward sales of their PII by organizations that hold that information.  A full discussion of what CCPA entails is out of scope. In this article, I want to focus how our Information Protection Lifecycle (IPLC) and Framework can help organizations prepare for CCPA. 

What is considered PII under CCPA?

Essentially, anything that be used to identify individuals or households of California residents. A summarized list (drawn from the text of the law) includes:

  • Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, SSN, driver’s license number, passport number, or other similar identifiers.
  • Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Biometric information.
  • Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.
  • Geolocation data.
  • Professional or employment-related information.
  • Education information, defined as information that is not publicly available.
  • Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

The list of data types that are designated as PII by CCPA is quite extensive.

How does a company or organization that is subject to CCPA go about protecting this information from unauthorized disclosure?

The IPLC offers a place to start. Discovery/classification is the first phase in the IPLC. You have to understand what kinds of information you have in order to know if you’re subject to CCPA (or any other pertinent regulations). As with GDPR, a Data Protection Impact Assessment (DPIA) type exercise is a good first step. Organizations that have, sell, or process California resident PII need to conduct data inventories to discover what kinds of PII they may have. There are automated tools that can greatly improve your chances of finding all such data across disparate systems, from on-premise applications and databases to cloud-hosted repositories and apps. Many of these tools can be quite effective, due to the well-known formats of PII. For example, Data Leakage Prevention (DLP) and Data Classification tools have been finding and categorizing data objects such as SSNs, credit card numbers, email addresses, driver’s license numbers, etc. for years.

DLP and classification tools generally provide two ways of applying those classifications to data objects:

  • Metadata tagging – adding data about the data to the object itself to signify what type it is and how it should be handled by applications and access control / encryption systems. This method works well for unstructured data objects such as XML, Office documents, PDFs, media files, etc. In some cases, the metadata tags can be digitally signed and encrypted too for additional security and non-repudiation.
  • Database registration – adding database elements (additional tables, or columns and rows) to databases to indicate which rows, columns, or cells constitute certain data types. This is usually needed for applications that have SQL or NoSQL back-ends that contain PII, since metadata tagging will not work. This approach is more cumbersome and may require database access proxies (or API gateways) to mediate access and integrate with centralized attribute-based access control (ABAC) systems.

Thus, we see that the first phase in IPLC and the tool types related to that phase (Discovery/Classification) are the way to begin preparing for CCPA enforcement. For additional information on these kinds of tools and more guidance on CCPA and GDPR, see https://plus.kuppingercole.com/. Also, watch our blogs in the days ahead as we will be publishing more about CCPA and how to prepare.


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