PRGN-03

Does your solution process personal data regulated by state law(s) (e.g., CCPA)?

Explanation

This question is asking whether your software solution or service processes personal data that falls under the jurisdiction of various state privacy laws, such as the California Consumer Privacy Act (CCPA) or similar laws in other states (like Virginia's CDPA, Colorado's CPA, etc.). Personal data typically refers to information that can identify an individual, either directly or indirectly. State privacy laws regulate how businesses collect, process, store, share, and protect this data, and they grant specific rights to consumers regarding their personal information. This question is being asked in a security assessment because: 1. Compliance requirements: If your solution processes data regulated by state privacy laws, you must comply with specific requirements regarding data handling, consumer rights, and security measures. 2. Risk assessment: Processing regulated personal data increases the risk profile of your solution, as non-compliance can lead to regulatory penalties, legal action, and reputational damage. 3. Data protection obligations: State privacy laws often mandate specific security measures for protecting personal data, which the assessment needs to verify. To best answer this question: - Be specific about which state privacy laws apply to your solution - Identify what types of personal data your solution processes - Briefly mention how you ensure compliance with these laws - If you're uncertain, it's better to err on the side of caution and indicate that your solution may process regulated data Remember that even if you don't specifically target consumers in certain states, if you collect data from residents of those states, their privacy laws may still apply to your operations.

Example Responses

Example Response 1

Yes, our solution processes personal data regulated by state privacy laws including the California Consumer Privacy Act (CCPA), Virginia's Consumer Data Protection Act (CDPA), and Colorado's Privacy Act (CPA) We collect and process customer names, email addresses, IP addresses, and browsing behavior from users across the United States To ensure compliance, we maintain a comprehensive privacy program that includes data mapping, privacy notices, consent management, and processes to fulfill consumer rights requests (access, deletion, opt-out of sale/sharing) We regularly review and update our practices as new state privacy laws are enacted.

Example Response 2

Yes, our solution processes personal information subject to the California Consumer Privacy Act (CCPA) and similar state laws While our primary customer base is businesses (B2B), we collect limited personal information from end users for authentication purposes, including names, business email addresses, and access logs We've implemented a privacy compliance framework that includes: (1) data minimization practices, (2) role-based access controls, (3) documented retention policies, and (4) procedures for responding to consumer rights requests We also maintain transparency through our privacy policy that discloses our data practices and available consumer rights.

Example Response 3

No, our solution does not currently process personal data regulated by state privacy laws such as CCPA Our product is a specialized industrial monitoring system that collects and analyzes machine performance data and environmental readings from manufacturing equipment The data we process is limited to non-personal technical information such as temperature readings, pressure levels, equipment uptime statistics, and maintenance logs We do not collect, process, or store any personal information that would identify individual consumers or employees However, we recognize that privacy regulations continue to evolve, and we conduct annual assessments to ensure our data handling practices remain compliant with applicable laws.

Context

Tab: Privacy
Category: General Privacy