The California Privacy Rights Act (CPRA) is an amended version of the California Consumer Privacy Act (CCPA). The CPRA was passed in 2020 and took effect on January 1, 2023.
CPRA’s requirements emphasize cookie notice and user choice. The law also contains other requirements, regulating the purposes for which businesses can collect personal information, and the Personal Information retention periods.
The data minimization principle is among the many distinctions between the CPRA and the CCPA. The CPRA contains the first data minimization requirement of any US privacy law.
This guide will help you understand CPRA data minimization and implement it correctly.
What Is CPRA Data Minimization?
Data minimization means limiting the Personal Information you collect, use, share, and store to what is reasonably necessary and proportionate to achieve the intended purpose.
It means that you can't collect excessive personal information. Excessive personal data violates your customers' privacy, and the more personal information you control, the more likely you are to suffer a data breach.
The data minimization principle allows you to collect just what it is needed for a specific purpose, and nothing more.
This concept isn’t new — it’s a legal requirement of Europe’s GDPR and other privacy regulations.
CPRA sets a legal requirement to data minimization for businesses operating in California.
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CPRA Data Minimization Requirements
The CPRA mandates two important principles of lawful data processing:
- Purpose limitation
- Storage limitation.
Purpose limitation under the CPRA
The CPRA sets the data minimization principle through Section 1798.100(c), mandating businesses to limit personal data collection, use, retention, and sharing to what is “reasonably necessary and proportionate” to achieve:
- The original purpose for which the personal information was collected; or
- Another disclosed purpose that is compatible with the context in the earlier collected personal information.
Thus, the CPRA’s data minimization principle states:
- Businesses should only collect, use, keep, and share consumers’ personal information to what is reasonably necessary for a specific purpose.
- The personal data collected must be reasonable and proportionate to the original purpose for which the business collected the personal information or for another disclosed and compatible purpose.
- Further processing of personal information for purposes incompatible with the original purpose is prohibited (purpose limitation).
The CPRA’s section 7002(d) provides the standard that helps to determine whether the collection, use, retention, or sharing of a consumer’s personal information is reasonably necessary and proportionate to the disclosed purpose:
- The minimum amount of personal information required to accomplish a processing purpose was obtained. For example, if a person buys a good, a business could require to provide payment and delivery information, order details, and an email to send an email confirmation of the purchase. Businesses shouldn’t ask for age, sex, geolocation, or other irrelevant data.
- The potential risks to the consumers posed by the collection or processing of their personal information by the business. For example, gathering health data, sex, religion, accurate geolocation, and other sensitive personal information data may cause a potential risk for consumers and thus should be avoided.
- The use of safeguard mechanisms. For example, to protect consumers’ data, businesses may consider data encryption or the automatic erasure of personal data when it is no longer needed.
- The CPRA through the section 7002(e) further mandates that businesses should notify the relevant consumers about the original purpose for which the information will be collected and obtain their consent prior to the collection or use of additional categories of personal information.
To comply with the purpose limitation principle of the CPRA, follow these best practices:
- Eliminate unnecessary fields in data collection forms.
- Conduct regular audits to evaluate data relevance.
- Implement consent management tools to control data collection and user consent.
Storage limitation under the CPRA
The CPRA, through section 1798.100 (a)(3) also outlines storage limitation. Businesses should inform the consumers how long they intend to retain each category of the consumer’s personal information.
Whether the business cannot provide an accurate timeline at the time of data collection, it should inform the consumer of the criteria used to determine the data retention period. However, the business must not store personal data beyond the period reasonably necessary to achieve the original purpose.
To comply with the storage limitation principle of the CPRA, follow these best practices:
- Establish clear data retention policies that meet your business practices.
- Implement automated data deletion schedules.
- Regularly review stored data and delete outdated information.
Third parties and data minimization obligations
Businesses often sell or share data with service providers or other third parties for different business purposes, such as advertising or business analytics.
Any contractors, service providers, or third parties should comply with the CPRA and the data minimization principle.
The CPRA, through section 1798.100 (d), mandates the requirements for such data sharing or selling for third parties. In such cases, businesses must enter into an agreement with third parties that outlines the following terms and conditions:
- the business is selling or sharing personal information only for specific purposes;
- the third party shall comply with all applicable CPRA privacy requirements;
- the business shall have the right to control the data processing activities of third parties to ensure that it uses the disclosed personal information in a CPRA-compliant way;
- the third party is obligated to notify the business if it determines that it can no longer meet its obligations under the CPRA; and
- the business shall have the right, upon notice, to take reasonable and appropriate steps to stop and remediate unauthorized use of personal information.
How to Achieve CPRA Data Minimization in 2025?
Follow these best practices to achieve CPRA data minimization in 2025:
- Define clear personal data collection purposes.
- Establish clear data retention policies that meet your business practices.
- Limit data retention by implementing automated data deletion schedules, regularly reviewing stored data, and deleting outdated information.
- Limit data collection by eliminating unnecessary fields in data collection forms and conducting regular audits to evaluate data relevance.
- Implement consent management tools to control data collection and user consent.
- Conduct data inventory. Know what personal data you collect, where it comes from, and why you collect it. Use tools like CCPA data mapping and data privacy assessments (DPIA).
- Minimize data sharing. Review your third-party relationships and ensure that you share only the relevant data needed for approved purposes. Check that your agreements with third parties meet the above-mentioned terms and conditions.
Common Mistakes with CPRA Data Minimization
Even if businesses know the best practices of the CPRA data minimization best practices, they sometimes make mistakes. Read the following mistakes to avoid them:
- Over-collecting: Many businesses gather more data than is necessary to achieve specific purposes.
- Too long data storage time: Some businesses store data for longer than required for specific purposes. This happens when businesses don’t use periodic reviews of data collected.
- Outdated data collection or retention policies. Some businesses create data collection or retention policies and use them for years without making any changes until they become outdated. There are constant changes in the requirements of data privacy regulations.
- Lack of data inventory: When businesses don’t know what personal data they possess and how it was collected, it is difficult to track and limit data collection.
- Ignoring third-party compliance: Businesses sometimes forget to ensure CPRA requirements of service providers and other third parties.
- Lack of employee training: If staff are not properly trained on CPRA's requirements, they may inadvertently apply the data minimization principle through data collection or retention mistakes.
How CookieScript Can Help to Comply with the CPRA?
CookieScript Consent Management Platform (CMP) helps businesses to comply with major privacy laws worldwide, including the CPRA.
In 2024, users ranked CookieScript CMP on G2, a peer-reviewed website, as the best CMP for small and medium-sized companies.
CookieScript CMP has the following features needed to comply with the CPRA:
- Customizable cookie banners
- User consent recording
- Geo-targeting feature
- Automatic monthly Cookie Scanner
- Global privacy compliance
- Easy-to-implement solutions, comprehensive manuals, and technical support
- IAB TCF v2.2 compliant
- Google CMP gold partner.
Frequently Asked Questions
What is CPRA data minimization?
Data minimization means limiting the amount of personal information you collect, use, share, and store to what is reasonably necessary and proportionate to achieve the intended purpose. CPRA imposes this legal requirement to data minimization for businesses operating in California. Use CookieScript CMP to comply with the CCPA, CPRA, and other privacy laws.
What are CPRA data minimization requirements?
The CPRA mandates two important principles of lawful data processing: purpose limitation and storage limitation. Purpose limitation requires to limit personal data collection and use to what is “reasonably necessary and proportionate”, while storage limitation deleting data when it is no longer needed for the purpose collected. CookieScript CMP can help you to comply with the CCPA and CPRA.
How to achieve CPRA Data Minimization in 2025?
To achieve CPRA data minimization in 2025, follow these best practices: define clear personal data collection purposes, establish clear data retention policies, limit data collection and retention, implement consent management tools, conduct data inventory, and minimize data sharing. CookieScript CMP can help you to achieve CPRA data minimization.
What are the penalties for failing to comply with CPRA data minimization requirements?
Failure to comply with CPRA's data minimization requirements can lead to fines from $2500 (non-intentional violation) up to $7500 (intentional violation). The California Privacy Protection Agency and the Attorney General enforce the law. Use CookieScript CMP to comply with the CCPA and CPRA and to avoid penalties.
