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What Does the CCPA Require You to Redact?

Neetusha
Neetusha · Founder & CEO of RedactifyAI ·

The CCPA requires businesses to redact third-party personal information from documents before disclosing them in response to consumer access requests, and to treat stored documents as candidates for proactive redaction to qualify for the Section 1798.150 safe harbor. The law does not use the word "redaction" throughout, but the obligation is built into how its consumer rights work.

The three situations that create a redaction obligation

Consumer access requests (DSARs). Under Section 1798.100, consumers can request the personal information a business holds about them. When you respond, you must disclose the requester's data but redact any personal information belonging to other people in the same documents. Handing over a contract that includes another person's Social Security number alongside the requester's name is a violation. Businesses have 45 calendar days to respond, extendable to 90.

Right to opt-out. When a consumer opts out of the sale or sharing of their data under Section 1798.120, any documents containing their personal information must be redacted before further sharing continues.

Breach safe harbor. Section 1798.150 gives consumers the right to sue after a breach involving "nonencrypted and nonredacted personal information." Businesses that redact stored documents proactively can block that lawsuit even if a breach occurs.

What the CCPA does not require you to redact

Over-redaction is a compliance risk too. The CCPA does not require redaction of the requesting consumer's own data (that is what they asked for), aggregated or properly de-identified information, publicly available information the consumer made public themselves, or business contact information used in a purely commercial context.

How this differs from HIPAA and GDPR

HIPAA specifies exactly 18 Safe Harbor identifiers to remove from patient records. GDPR requires redaction under the data minimization principle but has no equivalent to the CCPA's class-action safe harbor. The CCPA covers 11 broad categories of personal information and applies to consumer data across any industry, not just healthcare or organizations with EU operations. For a side-by-side comparison, see our CCPA vs GDPR redaction guide.

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