While nearly everyone was focusing on the results of the 2020 Presidential race, California voters passed Proposition 24, the California Privacy Rights Act (CPRA) (full text here). You might be wondering if this is a new privacy law that will replace the 2018 California Consumer Privacy Act (CCPA), which went into effect earlier this year. The CPRA provides additional context to the CCPA and attempts to close some of the loopholes and ambiguity found in the original. The CPRA gives additional rights to consumers and places additional obligations on businesses.
While some of the CPRA changes will take effect immediately, most will not become enforceable until July 1, 2023, and apply only to personal information collected after January 1, 2022. Like the run-up to the launch of CCPA, companies will have time to prepare for the new requirements.
In scope, the CPRA retains the same basic structure as the CCPA. It includes establishing a dedicated enforcement agency for consumers, tripling fines against companies that violate kids’ data privacy, and making it harder to weaken privacy laws in the future.
A couple of the more notable additions in the CPRA are that the law expands the right to opt-out of sharing of information and establishes new rights to limit how businesses use “sensitive personal information,” a new term defined broadly to include, among other things: information about health conditions, genetic data, race and ethnicity, sexual orientation, precise geolocation, and more.
ERP applications already store an abundance of personally identifiable information, such as Social Security numbers, driver’s licenses, or passport numbers. This new data classification adds to the effort of identifying and classifying information necessary to remain in compliance.
The CCPA and CPRA require organizations to implement appropriate security measures around personal data privacy and satisfy consumer requests to opt-out of “sharing” and “selling” of their information. That means businesses must know what personal data they collect and how that data is accessed and used. However, companies using PeopleSoft, SAP ECC, S/4HANA, and Oracle E-Business Suite are likely facing significant compliance challenges due to inherent limitations that plague legacy ERP systems. Traditional ERP application logs do not produce the required level of granularity into how data is accessed.
Successful organizations will invest in technologies that monitor user behavior around data access and usage. This is where Appsian360 becomes an essential tool for compliance, as it expands native ERP logging capabilities to capture contextual details like what data was accessed, where it was accessed from, user IDs, IP addresses, pages accessed, actions performed, and more – information that is paramount for compliance reporting.
With the CPRA, Californians will likely have the most robust online privacy rights in the world. And it probably won’t be the last. The original passage of the CCPA incentivized other states to draft their own privacy bills. There’s been activity at the federal level as well. So, while the pandemic rightfully slowed down state and federal activity, there’s a good chance we’ll see additional privacy bills in 2021.
There’s no better time than the present to press forward with your compliance efforts, whether it’s for CCPA, GDPA, and now CRPA. Contact us to learn how Appsian can fast track your CCPA and CRPA compliance efforts by enhancing your visibility into data access and usage.
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