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:

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.


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Learn How RICHT Can Help You Navigate The California Consumer Privacy Act (CCPA)



    CCPA News


    • Disney’s Record CCPA Settlement: The California Attorney General secured a $2.75 million settlement with Disney over allegations of failing to honor consumer opt-out requests across various streaming platforms and devices. This enforcement action highlights the state’s rigorous focus on unified, user-friendly privacy controls. OUR TAKEAWAY: Organizations must synchronize opt-out mechanisms across all digital silos to ensure compliance with the Attorney General’s expectation of a seamless, identity-based privacy experience. Read More →
    • CCPA Bolsters Private Privacy Actions: The court held that CCPA standards shape reasonable privacy expectations, even without a direct private right of action. This allows plaintiffs to use statutory norms to strengthen common law invasion of privacy claims regarding unauthorized cookies. OUR TAKEAWAY: Companies must recognize that CCPA compliance now serves as a critical benchmark for common law liability, effectively creating a private litigation workaround through “norm-shaping” judicial interpretations. Read More →
    • California Privacy Enforcement in 2026: A Discussion with CalPrivacy’s Tom Kemp: This article examines the anticipated shift toward aggressive enforcement under the California Delete Act, specifically detailing the 2026 implementation of the “DROP” mechanism for centralized consumer deletion requests. OUR TAKEAWAY: Organizations must audit their automated data deletion pipelines and ensure strict registration compliance for data brokers to avoid the high-volume, per-day penalties associated with the new centralized system. Read More →
    • Now it’s personal: How the new CCPA regulations impose personal accountability on designated individuals: The California Consumer Privacy Act (CCPA) regulations introduce significant changes by requiring businesses to designate specific individuals accountable for privacy, AI, and cybersecurity practices, who must submit filings under penalty of perjury to the California Privacy Protection Agency. These designated executives must have sufficient knowledge and authority to provide accurate risk assessments and cybersecurity audit certifications. The regulations also outline rigorous requirements for review, approval, and sub-certifications to support the integrity of these submissions. Companies must carefully choose qualified individuals, update governance and insurance provisions, and allocate resources upfront to meet these new personal accountability standards, which will come into effect in phases beginning in 2026. Read More →

    • California AG Secures $530,000 Settlement with Sling TV Over CCPA Violations:
      Attorney General Rob Bonta reached a $530,000 settlement with Sling TV after the DOJ’s investigation found the streaming service violated the California Consumer Privacy Act (CCPA). Sling TV made it confusing and difficult for users to opt out of the sale of personal data, misleading them with cookie settings and requiring unnecessary, burdensome steps. The company also failed to protect children’s privacy by lacking easy opt-out functionality in its apps and not offering proper parental controls or disclosures for kids’ data. Under the settlement, Sling TV must streamline opt-out methods, minimize data collection from children, add kid profile protections, and clarify parental privacy tools. This marks the first enforcement action targeting streaming services from the DOJ’s CCPA sweep and reflects California’s ongoing intensive privacy enforcement.
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    • California Continues Privacy Enforcement Streak with Order Against Tractor Supply Company
      On September 30, 2025, the California Privacy Protection Agency (CPPA) fined Tractor Supply Company $1.35 million for multiple violations of the California Consumer Privacy Act (CCPA), including failure to provide timely and updated consumer and job applicant privacy notices, inadequate opt-out mechanisms for sale/sharing of personal information via tracking technologies, and deficient contracts with service providers and third parties. The CPPA imposed extensive remedial actions requiring quarterly digital property scans, improved opt-out preference signal recognition, enhanced privacy notice compliance, employee training, and annual compliance certifications through 2029. This enforcement underscores the CPPA’s focus on privacy notices, data subject rights, HR data, cookie consent systems, and contractual compliance, signaling increased scrutiny ahead of new CCPA regulations taking effect in 2026.
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    • Key CCPA Regulation Changes Effective January 1, 2026
      California’s revised CCPA rules require businesses to confirm and display when opt-out requests—including Global Privacy Control signals—are honored, enforce active opt-in for cookie consent without consent inferred from closing banners, and ensure opt-in and opt-out processes are equally easy. Consumers can request personal data collected since January 1, 2022. Privacy policies must specify categories of personal data shared with service providers, and mobile apps must include privacy policy links in settings. New rules mandate timely opt-out notices for connected devices like IoT, AR, and VR. Automated decision-making, privacy risk assessments, and cybersecurity audit requirements phase in from 2026 to 2028, requiring increased transparency, governance, and reporting.
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    • CPPA Finalizes ADMT and Risk Assessment Rules: The California Privacy Protection Agency Board finalized rules requiring businesses to assess privacy risks from data processing involving personal data sales, sensitive info, or automated decision-making technology (ADMT). Consumers can opt out of ADMT only when it replaces human decision-making. The rules await approval from the Office of Administrative Law. Read More →
    • CCPA Compliance Reminder: Annual Update Requirement for Online Privacy Policies: For businesses subject to the California Consumer Privacy Act (CCPA), a compliance step often overlooked is the requirement to annually update the businesses online privacy policy. Read More
    • Healthline Media to Pay Record California Privacy Penalty: Healthline Media LLC will pay $1.55 million in penalties for privacy violations under a pending settlement with California Attorney General Rob Bonta. The settlement announced Tuesday is the largest for violations under the California Consumer Privacy Act. The website publisher didn’t allow consumers to opt out of targeted advertising, and it shared data without the proper protections in place, according to Bonta’s office. Read More→
    • District Court Rulings Could Signal Expansion of California Consumer Privacy Right of Action: In two recent rulings, judges in the U.S. Northern District of California have allowed proposed class actions under the California Consumer Privacy Act (CCPA) to proceed without an allegation of a data breach, departing from past precedent. The CCPA contains a limited private right of action that allows individuals to bring suit if personal data about them is exposed via “unauthorized access, exfiltration, theft, or disclosure” due to a business’s failure to implement “reasonable security measures.” Read More→
    Hunton

    CPPA Fines Honda $632,500 for CCPA Violations

    On March 12, 2025, the California Privacy Protection Agency (“CPPA”) announced that it reached a settlement with American Honda Motor Co. (“Honda”) in which Honda will pay a $632,500 fine to resolve claims that the company violated the CCPA. The enforcement action comes as part of the CPPA’s ongoing investigation into connected vehicle manufacturers, which began in 2023.

    CCPA
    Compliance Week

    SpongeBob Game Developer Ordered To Pay $500K Over CCPA, COPPA Violations

    Popular children’s mobile game developer Tilting Point Media (TPM) agreed to pay $500,000 to settle allegations the company illegally collected children’s personal data, a violation under the California Consumer Privacy Act (CCPA) and a federal children’s privacy law.

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    COPPA
    Privacy Law
    The Record

    California AG Settles With DoorDash Over Selling Consumer Data Without Notice

    The food delivery service company DoorDash settled charges with California’s attorney general after state authorities alleged the company sold consumers’ personal information without notice and without giving them a chance to opt out, both violations of California’s strict consumer privacy law.

    CCPA
    Privacy Law
    IAPP

    California Attorney General Issues CCPA Violation Notices To Streaming Services

    California Attorney General Rob Bonta announced his office is issuing notices to streaming service providers for their alleged violations of the California Consumer Privacy Act. The letters specifically address the streaming service providers’ level of compliance for offering users easy opt-out mechanisms for the sale of their personal data.

    CCPA
    Privacy Law
    IAPP

    California Attorney General Announces First CCPA Enforcement Action

    California Attorney General Rob Bonta announced the first enforcement action under the CCPA, a $1.2 million settlement with multinational retailer Sephora over violations of the law’s “Do Not Sell” provisions.

    CCPA
    Privacy Law
    IAPP

    Top-10 Takeaways From The California AG’s CCPA Enforcement Case Examples

    In July, the office of the attorney general of California marked the one-year anniversary of its enforcement of the California Consumer Privacy Act by issuing a press release to tout its “successful enforcement efforts.”

    CCPA
    Privacy Law

    Privacy & Cybersecurity Practice Insights