HR Glossary | HR Cloud | 3 minute read

CCPA Compliance

CCPA compliance refers to meeting the requirements of the California Consumer Privacy Act, a state privacy law that gives California residents rights over their personal information.

Since the law was amended by the California Privacy Rights Act (CPRA), it explicitly covers employee and job applicant data too, not just customer data, which is where it becomes a direct HR compliance issue.

SHRM has flagged this employee-data expansion as one of the least understood parts of the law among HR teams focused mainly on customer privacy.

Does the CCPA Apply to Every Employer?

No. The CCPA generally applies to for-profit businesses that do business in California and meet at least one threshold: over $25 million in annual revenue, buying or selling personal information on 100,000+ consumers or households, or deriving 50%+ of revenue from selling personal information.

A company doesn't need to be based in California to be covered; it just needs California employees, applicants, or customers and to meet one of the thresholds.

What Employee Data Does the CCPA Cover?

Personal identifiers like name, address, Social Security number, and employee ID
Professional and employment-related information, including performance reviews
Biometric data, if collected for things like timekeeping systems
Internet or network activity, where relevant to work devices and systems
Inferences drawn from any of the above, such as performance predictions

What Rights Do California Employees Have Under the CCPA?

Right	What It Means
Right to know	What personal data is collected and how it's used
Right to delete	Request deletion, subject to legal retention exceptions
Right to correct	Fix inaccurate personal information
Right to limit use	Restrict use of sensitive personal information for certain purposes

How Should HR Approach CCPA Compliance?

The California Privacy Protection Agency actively enforces these requirements and has issued specific guidance clarifying how they apply to the employment context.

A centralized HRIS makes it far easier to locate and respond to a data request accurately, instead of searching across scattered spreadsheets, time and attendance logs, and email threads.

Maintain a clear inventory of what employee data is collected, where it's stored, and why
Provide a privacy notice specifically covering employee and applicant data, separate from a general customer-facing policy
Build a process to respond to employee data requests within the law's required timeline, using employee self-service to route and track them
Limit data retention to what's actually needed, rather than keeping records indefinitely by default

How Does CCPA Compliance Fit Into a Broader HR Data Strategy?

California isn't the only state with a comprehensive privacy law anymore; several other states have passed similar legislation, often with overlapping but not identical requirements.

Building data practices around the CCPA's standard, including clear onboarding disclosures about what's collected and why, tends to put employers ahead of most other state requirements too.

This connects to several other terms in HR Cloud's HR glossary, particularly record retention requirements.

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Frequently Asked Questions

Q: Does the CCPA require employee consent to collect personal data?

A: Not in every case, but it does require clear notice about what's collected and why, plus specific rights the employee can exercise afterward, like the right to know or delete.

Q: Can an employee request their entire personnel file under the CCPA?

A: The CCPA gives a right to know and access personal information, though certain records may be exempt or subject to other legal retention requirements that limit deletion.

Q: Does the CCPA apply to remote employees outside California?

A: It generally applies based on California residency, so a California resident working remotely for an out-of-state company can still be covered.

Q: What happens if an employer doesn't comply with the CCPA?

A: Enforcement can include administrative fines from the California Privacy Protection Agency, and certain data breaches can also trigger a private right of action.

Q: Is the CCPA the same as GDPR?

A: No. They share some similar concepts, like data access and deletion rights, but they're separate laws with different scopes, thresholds, and enforcement mechanisms.