The California Consumer Privacy Act (CCPA) is reshaping how mobile apps handle user data. Here’s what you need to know:

• Who It Affects: Apps with over $25M in annual revenue, 100,000+ users’ data, or earning 50%+ revenue from selling data.
• Key Requirements:
  • Disclose data collection practices (like device IDs and IP addresses).
  • Provide tools for users to access, delete, or opt out of data sharing.
  • Secure data with encryption and access controls.
• Enforcement: Violations can lead to fines up to $7,988 per incident. Notable cases include Sephora ($1.2M fine) and DoorDash ($375K fine).
• Common Mistakes: Missing “Do Not Sell” links, ignoring Global Privacy Control (GPC) signals, and unregulated data sharing.

Quick Tip: Start with a data audit, update your privacy policy, and use tools like OneTrust or Osano to simplify compliance. Staying compliant isn’t just about avoiding fines - it builds user trust and protects your business.

CCPA Core Requirements for Apps

Data Collection Disclosure

App developers must provide clear and upfront notices about the data they collect, such as device identifiers, IP addresses, and household information [1]. These notices should explain how the data will be used and be easily accessible - ideally within the app’s settings - before any data is collected. Include all data categories and their purposes in this notice [3]. If your app sells or shares user data, you are required to display a prominent “Do Not Sell or Share My Personal Information” link [3].

The CCPA also emphasizes the importance of safeguarding user rights alongside these disclosures.

User Privacy Rights

The CCPA grants app users specific rights that developers are obligated to honor within designated timeframes. Businesses must provide at least two ways for users to submit requests, such as a toll-free phone number. For apps, an interactive web form should also be available [4].

Here’s how to handle user requests:

• Access Requests: Confirm receipt within 10 days and provide the requested data within 45 days.
• Deletion Requests: Use a two-step confirmation process to verify the request.
• Opt-Out Requests: Complete the opt-out process within 15 days and inform third parties who received the user’s data in the past 90 days.

“A major factor for those seeking to comply is implementing a process for managing consumer requests under CCPA – similar to data subject access requests under GDPR.” - TrustArc [4]

Protecting user data is a critical element of these privacy rights.

Data Security Requirements

To support these privacy measures, the CCPA enforces strict data security standards. Key practices include:

• Encryption: Apply strong encryption for both stored and transmitted data.
• Access Controls: Implement strict authentication and authorization protocols.
• Regular Testing: Perform routine security assessments and penetration tests.
• Incident Response: Keep breach notification procedures updated and ready.

Additionally, businesses must retain records of privacy-related activities and user requests for 24 months [5].

Mobile app privacy enforcement push from CA Attorney General

CCPA Enforcement Examples

Recent cases highlight California’s active approach to enforcing privacy laws for mobile apps, with hefty fines serving as a clear warning to developers about meeting compliance standards.

Major Fines and Penalties

California’s Attorney General and the California Privacy Protection Agency (CPPA) have been aggressive in addressing violations of the California Consumer Privacy Act (CCPA). Here are two notable cases:

Sephora’s $1.2 Million Settlement (2022)
Sephora agreed to pay $1.2 million after being cited for multiple compliance failures:

• Not disclosing the sale of consumer data
• Failing to honor Global Privacy Control (GPC) signals
• Ignoring opt-out requests
• Missing the 30-day window to address violations [2]

“Technologies like the Global Privacy Control are a game changer for consumers looking to exercise their data privacy rights. But these rights are meaningless if businesses hide how they are using their customer’s data and ignore requests to opt-out of its sale. I hope today’s settlement sends a strong message to businesses that are still failing to comply with California’s consumer privacy law. My office is watching, and we will hold you accountable.” – AG Rob Bonta [6]

DoorDash’s $375,000 Fine (2024)
DoorDash was fined $375,000 for sharing customer data with a marketing cooperative without obtaining explicit consent [2].

These cases underline recurring compliance issues and highlight the challenges businesses face in adhering to privacy laws.

Top Compliance Mistakes

Mobile apps often struggle with specific CCPA requirements, leading to common violations. Here’s a breakdown of frequent mistakes and how to avoid them:

Two shifts in enforcement are worth noting:

• The 30-day cure period for violations has been removed.
• There is heightened scrutiny on compliance with Global Privacy Control requirements [6].

“The Attorney General’s focus is on compliance with the law, giving consumers choices and control. But the intent is not to run up revenue in California’s privacy fund. It’s to encourage compliance.” – Melissa G. Powers, Associate at LewisRice [6]

These enforcement actions make it clear: mobile app developers must prioritize compliance to navigate the evolving privacy landscape while maintaining their marketing goals.

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CCPA Compliance Guide

Staying on top of compliance is crucial for mobile apps, especially in light of recent enforcement actions. Here’s a practical guide to help you navigate the key steps.

Data Audit Steps

Start by creating a detailed inventory of all user data your app collects, processes, and shares. Here’s how to approach it:

• Identify Data Collection Points: Document every source of data entry, such as registration forms, purchases, analytics tools, and third-party SDKs.
• Categorize the Data: Break it down into types like:
  • Identifiers (e.g., name, email, device ID)
  • Commercial data
  • Online activity
  • Geolocation
  • Biometric details
  • Professional information

Privacy Policy Updates

Your privacy policy must clearly explain your data practices to comply with CCPA. Use the table below as a guide:

These updates are essential for handling user rights requests effectively.

User Rights Management

To comply with CCPA, you need systems that handle privacy requests within 45 days. Here’s what to focus on:

• Access Requests:

  • Add a privacy dashboard within your app.
  • Pre-fill forms with user identifiers for convenience.
  • Use device ID tracking for users who aren’t registered.

• Deletion Requests:

  • Automate workflows to process data deletion.
  • Ensure third-party SDKs support data removal.
  • Keep detailed records of all deletion requests.

Data Security Setup

Protecting user data is a critical part of compliance. Here’s how to strengthen your security:

• Technical Measures:

  • Use end-to-end encryption for data in transit.
  • Encrypt stored data to keep it safe.
  • Set up strict access controls and authentication.
  • Conduct regular security audits.

• Third-Party Oversight:

  • Check that all SDKs you use comply with CCPA.
  • Document how data is shared and provide opt-out options.
  • Periodically review the security practices of all third parties.

For example, the Flurry SDK includes an opt-out API that respects user preferences and manages data deletion requests [1].

CCPA Compliance Resources

To meet CCPA standards, app developers need the right tools to simplify compliance processes. Investing in data privacy not only builds trust but can also yield a return of up to $2.70 for every dollar spent [8]. Below are tools designed to make compliance assessments, privacy management, and app updates more manageable.

Compliance Assessment Tools

These tools help evaluate how well your app aligns with CCPA requirements:

These platforms provide automated gap analysis and real-time compliance tracking. For example, Osano helped Lattice reduce operational complexities, align marketing with compliance efforts, and maintain its privacy-first commitment [8].

Privacy Management Software

Privacy management tools focus on four main areas:

• Consent Management: Automatically collect and track user preferences.
• Data Discovery: Scan and catalog personal information.
• Request Automation: Handle user rights requests within the required 45-day timeframe.
• Third-Party Monitoring: Track how data is shared with external vendors.

Solutions like Usercentrics and iubenda deliver these features effectively. For instance, iubenda, rated 4.5/5 on Capterra, is known for its ability to help apps stay compliant while minimizing operational efforts [7].

Capgo: CCPA-Compliant App Updates

Beyond privacy management, platforms like Capgo ensure your app remains CCPA-compliant during updates. Capgo supports compliance by offering:

• End-to-end encryption to safeguard user data during updates.
• No cross-device tracking or persistent identifiers.
• Transparent data handling with aggregated-only statistics.
• User control through immediate account and data deletion options.

Capgo has successfully delivered over 492.4 million updates across 1,800 production apps, all while adhering to strict privacy guidelines [9].

“Capgo is a must-have tool for developers who want to be more productive. Avoiding review for bug fixes is golden.” - Bessie Cooper [9]

Using these tools alongside regular audits can help maintain consistent CCPA compliance.

Conclusion: CCPA Compliance Steps

Following the strategies discussed earlier, here’s a breakdown of the key actions to help ensure compliance with the CCPA. Staying compliant means taking a thorough approach to protecting user data in mobile apps. Recent enforcement cases highlight the risks of non-compliance, including hefty fines, so developers need to take privacy measures seriously.

Here are three main areas to focus on:

• Data Management and Transparency

  • Perform data inventories to map out all personal information collected, such as device identifiers and IP addresses [1].
  • Track and document how each user’s data is handled.
  • Clearly inform users about data collection practices before gathering any information.
  • Review third-party SDKs to confirm they meet compliance standards.

• User Rights Implementation

  • Set up systems to handle data access and deletion requests.
  • Ensure user requests are addressed within the required 45-day window.
  • Add an easy-to-find “Do Not Sell Or Share My Personal Information” link.
  • Create identity verification processes to manage user requests securely [10].

• Technical Infrastructure

  • Use end-to-end encryption to safeguard user data.
  • Store user consent securely.
  • Opt for privacy-focused update tools, such as Capgo.
  • Regularly run security audits and keep privacy policies updated.

For ongoing compliance, consider using tools designed to meet CCPA rules. For example, colenso shared their experience with Capgo:

“We rolled out Capgo OTA updates in production for our user base of +5000. We’re seeing very smooth operation almost all our users are up to date within minutes of the OTA being deployed to @Capgo.” [9]