Understanding the CCPA data subject access request (DSAR) process

The California Consumer Privacy Act (CCPA) gives California consumers some rights to control their personal information. Among these is the “right to know” (or the “right to access [data]”), which grants people the ability to request details about the data that a business collected from them, used, or sold. Businesses must respond to and process these data subject access requests (DSARs) in compliance with the CCPA.

What is a CCPA data subject access request (DSAR)?

A DSAR allows California consumers to request detailed information about their personal data from businesses. This includes data categories, specific personal details, data sources, purposes for data collection, and third-party data sharing.

Read more: DSAR meaning

Any person protected under the scope of the CCPA—or any other data privacy law with similar statutes, such as Europe’s General Data Protection Regulation (GDPR)—can submit a DSAR, and businesses catering to these consumers must comply with the regulations to fulfill these requests.

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What is the timeline for CCPA DSAR?

Under the CCPA, businesses must respond to DSARs within 45 days of receipt. If more time is needed, they can extend the deadline by an additional 45 days, provided they notify the consumer of the delay and explain the reason. This timeline ensures timely data transparency while allowing flexibility for complex requests.

What personal information can a consumer request access to?

The CCPA has a broad definition of “personal information” or “information that identifies, relates to, or could reasonably be linked with” a California consumer or household. Under the right to know, a consumer can request access to:

• The categories of personal information collected
• Specific pieces of personal information collected
• The categories of sources from which information is collected
• The purposes for which personal information is used
• The categories of third parties with whom personal information is shared
• The categories of information that is sold, disclosed, or in any way made available to third parties

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Do all businesses have to respond to DSARs?

The CCPA requires all for-profit businesses that do business in California and either has a gross annual revenue of over $25 million; buys, sells, or receives the personal information of more than 50,000 California residents, households, or devices; or derives at least half of their annual revenue from the sale of California consumers’ personal information must respond to and process DSARs.

Exceptions to the CCPA

Given its nature, does the CCPA apply to government agencies? The answer is no—with the same being true for non-profit organizations.

That said, if government entities and non-profits are third parties to whom a business shares information, the business must disclose that and list them in the category of third parties.

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Key components of a DSAR response process

The CCPA provides regulations as to how a business must respond to, process, and keep a record of DSARs in a way that fully enables consumers to exercise their afforded rights. Therefore a business must set a method for processing DSARs and explain it in detail in their CCPA privacy policy. Here are some steps that a business must take to comply:

1. Establish clear submission channels‍

Businesses must provide at least two methods for submitting DSARs—one being a toll-free number, the other being an email contact address (except if the business operates exclusively online, in which an email address should suffice). These channels should be fit for the nature of the business, and they should be separate from other customer support channels.

2. Authenticate requesters

Implement robust identity verification to ensure requests are legitimate while maintaining data security.

3. Organize data discovery and collection

Use automated tools to locate, classify, and compile requested data efficiently.

4. Respond within legal timeframes

Fulfill requests within 45 days, with a possible extension of 45 additional days if necessary.

5. Deliver comprehensive responses

Clearly outline the requested information, including categories and specific data points.

6. Maintain detailed records

Document DSAR requests, responses, and processing details for regulatory audits.

Go further: How to manage DSARs

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CCPA DSAR compliance best practices

Automate where possible

Use privacy management platforms to streamline DSAR workflows. Automation helps reduce manual workloads, ensuring timely and consistent responses while minimizing human errors. Privacy tools like Ketch will help you free your stakeholders from manual data subject rights (DSR) tasks.

Read more: DSR automation‍

Train employees

‍Ensure staff understands DSAR processes and compliance obligations through regular training sessions. Employees should be familiar with identifying DSAR requests, processing them correctly, and adhering to legal requirements.‍

Audit regularly

‍Conduct periodic reviews of DSAR handling procedures to identify potential compliance gaps. Internal audits help ensure that processes remain efficient, up-to-date with evolving regulations, and aligned with industry best practices.

Expanding compliance under CPRA

With the California Privacy Rights Act (CPRA) supplementing the CCPA, businesses must prepare for additional DSAR requirements, including expanded consumer rights and stricter compliance standards.

Effective DSAR management is crucial for maintaining consumer trust and regulatory compliance. By implementing efficient processes, leveraging automation, and staying updated on privacy regulations, businesses can handle DSARs effectively while safeguarding personal data.

Example: Respecting privacy choices at IMAX

IMAX needed a solution for California opt-outs (CPRA) and DSAR requests. By leveraging Ketch as their privacy management platform, IMAX streamlined its compliance efforts while building trust with its global audience. This partnership allowed IMAX to handle DSARs efficiently, ensuring legal compliance and fostering customer transparency.

The results? IMAX has automated 80% of all DSAR fulfillment, freeing up resources for other initiatives. With the Ketch App Marketplace, IMAX depends on Ketch privacy APIs to orchestrate privacy choices across data systems, and eliminates the need to build these costly integrations in-house.

“We’re impressed with Ketch’s App Marketplace. Ketch connects people’s privacy choices to our CDP and data systems—a truly comprehensive consent and rights solution.”

Senior Vice President, Legal and Business Affairs at IMAX

Free your stakeholders from manual DSR tasks with Ketch

Ketch's Data Permissioning Platform simplifies privacy operations by automating complex DSAR workflows. Its comprehensive solutions enable businesses to manage, monitor, and respond to DSARs effectively, ensuring compliance with CCPA regulations.

By adopting Ketch's tools, businesses can enhance transparency, build consumer trust, and responsibly leverage data for better customer engagement and sustainable growth.

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Effective DSAR management is crucial for maintaining consumer trust and regulatory compliance. By implementing efficient processes, leveraging automation, and staying updated on privacy regulations, businesses can handle DSARs effectively while safeguarding personal data.

For more help with CCPA compliance, contact the privacy experts at Ketch to learn more about consent management software and how it can help your business.

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