Not necessarily.

Although the CCPA’s definition of “consumer” includes employees that reside in California,1  the CCPA applies only to a “business” -- a term that is defined as being an entity that “does business in the State of California” and that meets one of the following three thresholds:

  1. Annual gross revenue in excess of $25 million,
  2. Purchase, receives for commercial purposes, sells, or shares for commercial purposes, personal information of 50,000 or more consumers, or
  3. Derives 50% of annual revenue from selling consumer personal information.2

The net result is that if a business meets one of the three thresholds established  for gross revenue, quantity of data points, or revenue-generated by the sale of personal information, and has California employees, then it will be subject to the CCPA.  If a business does not meet one of the three thresholds set forth above, but has California employees, then it will not be subject to the CCPA. 

For more information and resources about the CCPA visit 

This article is part of a multi-part series published by BCLP to help companies understand and implement the General Data Protection Regulation, the California Consumer Privacy Act and other privacy statutes.  You can find more information on the CCPA in BCLP’s California Consumer Privacy Act Practical Guide, and more information about the GDPR in the American Bar Association’s The EU GDPR: Answers to the Most Frequently Asked Questions.

1. Cal. Civil Code Section 1798.140(g).

2. Cal. Civil Code Section 1798.140(c)(1)(A)-(C).

This document provides a general summary and is for information/educational purposes only. It is not intended to be comprehensive, nor does it constitute legal advice. Specific legal advice should always be sought before taking or refraining from taking any action.