CPPA Releases Enforcement Advisory Urging Data Minimization Compliance

In a recent enforcement advisory issued by the California Privacy Protection Agency (CPPA), businesses were reminded to adhere to the foundational principle of data minimization outlined in the California Consumer Privacy Act (CCPA). The advisory, titled "Enforcement Observations," highlights the significance of minimizing the collection, use, retention, and sharing of consumers' personal information.

Data minimization serves multiple crucial functions, including reducing the risk of unauthorized access through data breaches and facilitating efficient responses to consumers' CCPA rights requests. Despite these imperatives, the CPPA's Enforcement Division has observed certain businesses requesting excessive and unnecessary personal information from consumers in response to CCPA requests.

The advisory underscores the necessity for businesses to apply data minimization to every purpose for which they handle consumers' personal information, including processing CCPA requests. Specifically, businesses are encouraged to assess their practices periodically from the perspective of data minimization to mitigate risks and enhance data governance.

The Enforcement Advisory, numbered 2024-01, further emphasizes the CCPA's stipulation that businesses must collect, use, retain, and share consumers' personal information only to the extent reasonably necessary for the intended purpose. Failure to comply with data minimization principles may result in regulatory actions by the CPPA.

Included in the advisory are hypothetical scenarios intended to guide businesses in evaluating their practices. These scenarios illustrate situations such as responding to consumer requests to opt-out of the sale or sharing of personal information and verifying a consumer's identity in connection with requests to delete personal information.

In the first scenario, businesses are reminded not to require consumers to verify their identity excessively when opting out of sale or sharing. Instead, businesses are encouraged to collect only the minimum necessary personal information for processing such requests, ensuring it is not burdensome on the consumer.

In the second scenario, businesses are urged to establish reasonable methods for verifying consumers' identities when fulfilling requests to delete personal information. Such methods should align with data minimization principles, avoiding unnecessary collection of additional personal information beyond what is already held by the business.

The enforcement advisory serves as a clarion call to businesses subject to the CCPA, urging them to review and align their practices with data minimization principles. By doing so, businesses not only enhance compliance with regulatory requirements but also reinforce consumer privacy and data protection standards in accordance with the CCPA's overarching objectives.

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