GDPR, CCPA and the newly coming CPRA (which goes into effect 1/1/2023) require intense data management, or the cost of non-compliance can rise to $1000 per record. These data privacy laws pertain broadly to personal information of consumers including:

  • Account and login information
  • GPS and other location data
  • Social security numbers
  • Health information
  • Drivers license and passport information
  • Genetic and biometric data
  • Mail, email, and text message content
  • Personal communications
  • Financial account information
  • Browsing history, search history, or online behavior
  • Information about race, ethnicity, religion, union membership, sex life, or sexual orientation

CPRA requires businesses to inform consumers how long they will retain data (for each category of data) and the criteria used to determine that time period of what is “reasonably necessary.” Basically, you have to be prepared to justify the data collection, processing, and retention and tie it directly to a legitimate business purpose.

Now prohibited is “sharing” data (beyond buying and selling it), which is defined as: sharing, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic of other means, a consumer’s personal information by the business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for the benefit of a business in which no money is exchanged. Arguably, this covers a business working with a marketing firm and sharing data with the agency about leads or prospects to employ cross-content behavioral advertising in a campaign.

Companies now need to be able to inform the consumer what type of data they have about customers, what business purposes it is used for, and retention periods. This information allows them to meet the expanded consumer rights given by the CPRA, including deleting data, limiting types of use for certain types of data, correcting data errors across the organization in every location where it lives, automating and executing data retention policies, and to be ready for auditing. While it is an ethical ruleset that has now been put in place, with Data Privacy Compliance active, companies now have to consider possible non-compliance costs in addition to operational and opportunity costs as well.

As a result of these requirements, companies are now in need of a data management system with built-in data governance to stay in compliance. These data management platforms must be capable of identifying, on a data field-by-data-field basis, where the data originates, each and every change made to the data, and each downstream user of the data (databases, apps, analytics, queries, extracts, dashboards). Without automated data management and governance, it will be humanly impossible to manually find this information by the deadlines required. You need to be able to automatically replicate changes made to the data to all locations where the data resides throughout your organization to make consumer directed corrections and deletions within the time limits prescribed.