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CCPA Update: Cybersecurity Requirements (Part 2)

The California Privacy Protection Agency (CPPA) has introduced new cybersecurity audit requirements for businesses subject to the California Consumer Privacy Act (CCPA). These regulations target organizations that meet specific revenue or personal information processing thresholds, mandating a rigorous annual audit process to ensure the protection of consumer data. The rollout is phased based on revenue, with the first wave of compliance tracking beginning in 2027 and the first official certifications due in early 2028.

Compliance involves 18 core cybersecurity requirements, including multi-factor authentication, encryption, and robust incident response planning. Organizations must ensure that audits are conducted by independent professionals with specific cybersecurity expertise. Crucially, executive management must certify the audit results under penalty of perjury, emphasizing the legal and administrative accountability for maintaining data security standards across all systems that process or transmit personal information.


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