CHAPTER 4: ROLES IN THE CPRA: BUSINESSES, BUSINESS PURPOSE, AND SERVICE PROVIDER

Considerable attention has already been given to what constitutes a “business” under the CPRA. As explained, “business” describes covered entities, those organizations primarily responsible for complying, and demonstrating compliance with the CPRA. This responsibility largely hinges on which organization in the data supply chain collects personal information, or directs the means and/or purposes for processing the information. This is similar to the GDPR’s understanding of a “data controller.”

Under the GDPR, there are both “data controllers” and “data processors.” Data processors process personal information on behalf of the data controller, usually based on explicit ...

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