Understanding differences between GDPR and CCPA compliance requirements for global organizations.
Jurisdictional Scope
GDPR (General Data Protection Regulation) applies to any organization processing EU residents' personal data. CCPA (California Consumer Privacy Act) applies to California residents' data. Global organizations must understand where their data comes from and which regulations apply.
Different Approaches
GDPR is comprehensive, covering all personal data processing and imposing strict requirements. CCPA is more narrow, focusing on consumer privacy and commercial data sales. GDPR is stricter on some points, CCPA on others.
Consent Requirements
GDPR requires explicit opt-in consent for most processing. CCPA allows opt-out for some processing but requires opt-in for sensitive data. Organizations must implement processes satisfying both frameworks.
Data Subject Rights
Both frameworks grant data subject rights: access, deletion, and portability. CCPA adds "do not sell" rights. Both frameworks require timely response to requests.
Penalties
GDPR violations can result in fines up to €20 million or 4% of revenue. CCPA violations result in up to $7,500 per violation or $2,500 per unintentional violation. Both regimes impose significant financial risk.
Compliance Strategy
Global organizations should implement compliance processes satisfying the stricter framework (GDPR) then adapt for less-strict requirements (CCPA).