The California Consumer Privacy Act (CCPA) (as amended by the California Privacy Rights Act [CPRA]) is a wide-ranging privacy and data protection law with compliance consequences for a broad line of business types. Similar to the European Union’s GDPR, the CCPA has an extraterritorial scope and applies to many companies that are not physically located in California. Enacted in 2018 and in effect from a compliance perspective since 2020, the CCPA imposes requirements that include specific privacy notices, such as via a privacy policy, implementation of data processing agreements (DPAs) with service providers, among others, honoring privacy rights of consumers, such as DSARs, and conducting privacy impact assessments. The law is regularly amended, such as the addition of protections for neural data under the umbrella of “sensitive” personal information.
The CCPA is enforced by the California Attorney General and, subsequent to the CPRA, also by the California Privacy Protection Agency (CPPA). In some situations, there are also private actions, including class or other mass actions. So far, we have seen a variety of enforcement actions, ranging from warnings to fines, including the following:
- $2.75 million settlement against Disney (February 2026)
- $1.4 million settlement against Jam City (November 2025)
- $530,000 against Sling TV (October 2025)
- $1.35 million against Tractor Supply Company (September 2025)
- $1.55 million against Healthline (July 2025)
- $345,178 against Todd Snyder (May 2025)
- $632,500 against Honda for CCPA Violations (March 2025)
- 1.2 million fine against Sephora
- Fine against a food delivery platform
- Gaming company for non-compliance with the child protection provisions of the CCPA and COPPA
- $27.5 million settlement against Thomson Reuters for selling Californians’ personal data
At RICHT, we provide clients with a comprehensive suite of legal services to ensure compliance with the CCPA and avoid regulatory enforcement and private litigation. Our approach takes a business-first perspective, understanding both business dynamics and goals, and aims to integrate compliance and risk mitigation within these confines.