California Consumer Privacy Act (CCPA) / California Privacy Rights Act

Orion Governance Use Case

Achieving Privacy Compliance

The CCPA and other State-centric Privacy Acts that are in effect or that are being launched are the result of unregulated practices, lack of accountability, standards and inaction by firms around the pervasive wide scale collection, buying, selling, sharing and transferring personal data without individual consent. And the non-disclosure of a data breach, hack, leak or loss of personal data that includes personally identifiable information, location information, shopping/viewing/surfing habits etc.

The CCPA is the 2020 law that enhances consumer privacy rights and provides consumer protections to residents of California in such matters. It requires:

  1. A privacy notice on the site and
  2. Provides the right to access,
  3. Provides the right to delete and
  4. Provides the right to opt-out

From these practices such as sharing with 3rd parties, being included in targeted marketing etc. Privacy laws from Colorado and Virginia, quickly follow suit and do similar things for those residents. They come into effect in 2023..
The CCPA was further strengthened when the CPRA was signed into law in 2020, and includes provisions for

  1. Firms doing business in California that with gross annual revenue of $25M, or
  2. Firms that derive more than 50% of their annual income from the sale of California consumer information, or
  3. Annually Buy, Sell or Share personal information of 50,000 California residents.
  4. The CPRA has a lookback period of data collected by business from Jan 1, 2022, even though the CPRA goes into effect on Jan 1, 2023. So take the time and provide these functional capabilities.

Business denial could end up costing you.

What Does the California Consumer Privacy Act Do?

Gives the Consumer Ownership

Grants the rights to tell a business not to share or sell personal information

Gives the Customer Complete Control

Our data governance experts understand how hard enterprises work to avoid compliance issues.

Gives the Customer Privacy Rights

Our data governance experts understand how hard enterprises work to avoid compliance issues.

This is part of a GDPR journey that every organization needs to take, including:

In some ways, CCPA goes farther than GDPR in the definition of consumer data and includes derived data into the protected bucket; “Information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household”.

Personal information categories include:

  • “Unique personal identifiers” (as defined):
    • Geolocation data
    • Purchasing, browsing and search histories
  • Biometric information; Notably, CCPA’s personal information includes “olfactory” and “thermal” information linked to a consumer or household
  • “Purchasing or consumer tendencies”; all of which are quite broad and indefinite.

Given this broad categorization, how then is consumer data to be identified? Not only do companies have to tag information that is collected directly but also data that is linked to the consumer based on actions and other business processes. For many organizations, conducting an initial assessment across disparate heterogeneous platforms is a daunting and time-consuming exercise.

Sophisticated scanners such as the Orion Enterprise Information Intelligence Graph can quickly and automatically examine different vendor databases across disparate technologies, file types and even determine where and how such personal data is linked and moving across the enterprise. In addition, the content, format, range of values, and data types must be compared in an automated fashion for similarities, differences, and compliance with data management and data security policies.

Orion’s Term2Asset module maps business glossaries and terms that describe consumer data using a broad brush into the specific physical data for semantic querying, and can vastly enable reporting and discovery for the business data steward. Finally, the results must be analyzed, documented, and communicated to a broad, diverse audience.

Below are some steps that every organization could follow:

Data discovery and Identification – Automated discovery of data assets and cataloging metadata and their respective schemas, definitions, types, sizes, and inter-dependencies. Personal and Customer data tends to be spread out across relational databases, archived records in a data lake / warehouse, and Distributed File System stores (e.g., Hadoop etc.). The Orion Governance platform supports all of these disparate technologies and can harvest data automatically.

Catalog external data sources – Vendor and third party data is often collected using different business processes than internal data, and may be used to enhance personal information through record matching and additional attributes.

Automatically document data flow and lineage – Data flow of various Critical Data Elements (CDEs) within the enterprise along with lineage is essential to ascertain where customer data moves, especially the primary customer identifiers, and sensitive personally identifiable data. Examples may be CRM systems like Salesforce, home-grown or SaaS applications such as email marketing), analytics tools, and other data stores. BI and/or reporting systems also tend to contain a lot of customer information that needs to be cataloged and included in the lineage process.

Implement a metadata repository and layer – Customer and prospect data may be spread across data stores, from transaction databases to marketing systems, under your control or through SaaS applications. A metadata layer is essential to help abstract different data sets and apply the proper restrictions on personally identifiable data.

Review data retention policies – While customer data cannot be deleted without a proper process in place, reviewing the company’s data retention policies with a metadata layer in place is a whole lot easier and provides the right level of visibility into these legal and regulatory processes that are essential for every company.

Orion Enterprise Information Intelligence Graph platform accelerates compliance in many specific areas.

Data Inventory

Orion EIIG Scanners discover all metadata (technical assets) to the finest grain

Data Inventory

Orion EIIG Term2Asset, through pattern matching and machine learning algorithm, automates data mapping to business glossary

Data Portability & Transformation

Orion EIIG data lineage (technical and business) provides insights on how data moves, transforms across systems end-2-end

Data Consumption & Metrics

Orion EIIG dashboard provides metrics on how data is being reported or consumed across systems

Data Deletion (Right to be Forgotten)

Search on any data (field, job, task, report, etc) – and find out data flows (lineage) end2end throughout all systems to confidently delete the record

Data Reporting

Orion EIIG Dashboard is configurable to meet reporting needs, in addition to REST API to extract data for external reporting

Keeping Data Customer-Centric

Business Problem

Most firms today are not set up with their data to be Customer-Centric. Their Customer data flows across many systems, departments, and gets shared/transferred with partners or 3rd parties. Being compliant with CCPA, GDPR and other state/national Privacy regulations requires you to be very Customer Centric, in order for the organization to be responsive and be able to quickly take the necessary steps in a timely manner (that is regulated with penalty implications when enforced).

The Orion Governance Solution

It would involve re-architecting things for your firm to become a Privacy-First organization and make it more Customer-Centric and Data-Centric (all 3 of which most firms aren’t). It would take time to put in place and involve multiple departments and partners getting trained in order to handle customer related privacy inquiries and putting things in place to ensure compliance. Orion EIIG is the one tool you want in your arsenal when you have such a high need to be Customer-Centric. It can help the organization gather all the necessary information to build the Customer/Employee/Vendor Master necessary to get a Customer-Centric agenda for Data Privacy underway.

Business Benefits with Orion Governance

CCPA is a law. Any firm that does business with Californians have to comply with the law. There are Customer initiated litigation consequences for non-compliance that are avoidable. Leveraging Orion EIIG you can put in place a solution that allows:

  1. Customers to see all the personal information your organization collects about them.
  2. Allows Customer to know if you are selling their information and to who it is being sold
  3. Decline to sale of personal information
  4. Have a view of their personal information as it exists in your organization

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