What settings in Spirion Sensitive Data Platform impact CCPA compliance?
The following settings and configurations are the most impactful for a CCPA-focused program:
1. Data Type & SDD Definitions (The "What")
CCPA defines "Personal Information" (PI) broadly, including identifiers, commercial information, and even "inferences."
- CCPA-Specific Data Types: Ensure you have enabled Data Types for California-specific identifiers, such as CA Driver’s Licenses, and broader PI like names, mailing addresses, and IP addresses.
- Sensitive Data Definitions (SDDs): Use SDDs to create "Contextual Matches." For example, a 9-digit number is just a number, but a 9-digit number near the word "Social Security" or within a "Payroll" folder is high-confidence PI. This reduces false positives during CCPA audits.
2. Target Segmentation (The "Where")
CCPA requires organizations to know where California residents' data is stored.
- Target Tagging: Use Target Tags to label repositories that contain California resident data (for example,
Region: CaliforniaorUserBase: CA). - Reporting by Segment: This allows you to generate a "CCPA Inventory Report" that excludes data from other regions, which is critical for proving "Reasonable Security" under the law.
3. Playbooks for "Right to Delete" & "Right to Know"
CCPA grants consumers the right to request the deletion of their data or a report on what data is held.
- Manual Remediation (Right to Delete): Configure playbooks that allow an operator to Shred or Redact specific files or database records identified during a Subject Access Request (SAR).
- Workflow Assignment: Use Workflows to assign a finding to a data owner with a "Due Date" to ensure the 45-day CCPA response window is met.
4. Agent-Side Redaction (Privacy by Design)
CCPA emphasizes protecting data even during the discovery process.
- Match Evidence Redaction: In the Agent Policy settings, enable partial redaction of match evidence (for example, showing only the last 4 digits of an ID).
- Why it matters: This ensures that your Spirion Console (and the people viewing it) does not become a new repository of unencrypted PI, which would increase your CCPA liability.
5. Search History (Incremental Compliance)
CCPA compliance is an ongoing obligation, not a one-time event.
- Search History Setting: Ensure Search History is enabled in your scan configurations.
- Impact: This enables you to run frequent "Drift Scans" to find new PI as it enters the environment without the performance hit of a full re-scan. This keeps your CCPA inventory current in near real-time.
6. Reporting & Audit Logs (The "Proof")
If audited, you must prove you have "Reasonable Security" and a repeatable process.
- Classification Logs: Use the Classification settings to apply persistent tags (like NTFS ADS or MIP labels) to files containing PI. This proves the data was identified and handled according to policy.
- Audit Reports: Regularly export reports from the Scan Results page showing "Found vs. Actioned" status to demonstrate active risk reduction.
Summary Checklist for CCPA
CCPA Requirement | Spirion Setting / Feature |
|---|---|
Data Inventory | Data Assets and Targets (with Target Tags) |
Broad PI Detection | CCPA Data Types and Contextual SDDs |
Right to Delete | Shred/Redact Playbooks |
Reasonable Security | Agent-Side Redaction and MIP/NTFS Classification |
Ongoing Monitoring | Scheduled Scans with Search History enabled |
By aligning these settings, you transform Spirion from a simple search tool into a CCPA Compliance Engine that provides the visibility and control required by California law.