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California announces investigative sweep for CCPA compliance



Eight of the top 10 metropolitan areas with the highest increase in pay transparency from February 2022 to February 2023 are in California, according to Indeed’s U.S. pay transparency research released in March.

Who is subject to the CCPA?

The CCPA applies to for-profit businesses that do business in California and meet any of the following:

  • Have a gross annual revenue of over $25 million
  • Buy, sell, or share the personal information of 100,000 or more California residents, households, or devices
  • Derive 50% or more of their annual revenue from selling California residents’ personal information.

However, even companies that do not exceed the dollar threshold may unknowingly become subject to the CCPA “through the use of website tracking technologies that share personal information, such as IP addresses and device identifiers (IDs), with cross-context behavioral advertising partners – and sometimes even unbeknownst to the business,” said Benjamin Perry, privacy lawyer in an Ogletree Deakins post.

“Thus, companies using such technologies can satisfy the second prong solely by collecting the personal information of 100,000 or more unique California website visitors annually – or roughly 274 unique visitors per day – without even taking into account California employees or consumers whose information they may be collecting directly. 

“In addition, even if these requirements are not met, the CCPA may still apply in certain circumstances where there is common ownership, branding with another entity subject to the CCPA, joint ventures, or partnerships between businesses.”

Read the full article here