How to Achieve CPRA Data Minimisation in 2025

The California Privacy Rights Act (CPRA) has raised the bar for data privacy, particularly with its emphasis on data minimisation. Businesses must ensure they collect, use, and store only the information necessary for business purposes. In 2025, with enforcement ramping up, compliance is crucial to avoid fines and build consumer trust. This guide will help you understand CPRA data minimisation and implement it effectively.

Data minimisation is a fundamental aspect of most privacy laws including the California Privacy Rights Act and the General Data Protection Regulation (GDPR). It helps businesses reduce risk and enhance consumer trust. In 2025, regulatory scrutiny might increase, making it more important than ever for companies to ensure they collect and retain only the information they truly need.

Consumers are also more privacy-conscious, demanding greater transparency and control over their personal information. Failure to comply with CPRA’s data minimisation principles can lead to legal penalties, reputational damage, and customer attrition.

By implementing data minimisation strategies, businesses can demonstrate their commitment to responsible data handling while reducing security vulnerabilities.

CPRA mandates that businesses must limit personal data collection, retention, and use to what is “reasonably necessary and proportionate” to achieve specific business purposes. This principle is embedded in California Civil Code Section 1798.100(c), reinforcing the need for responsible information handling practices.

According to the CPRA’s data minimisation principle:

• A business should only collect, use, keep, and share consumers’ personal information when necessary for a specific purpose.
• The personal data use must be reasonable and proportionate to the specified purpose for which it was collected.
• If using the data for a different purpose, it must still be closely related to the original purpose.
• Do not use personal data for secondary purposes that are incompatible with the original purpose (purpose limitation).

Failure to comply with the requirements can lead to regulatory penalties, reputational damage, and loss of consumer trust. The California Privacy Protection Agency (CPPA) and the Attorney General actively enforce these rules, making it essential for businesses to align their data processing activities with the law.

Businesses must define and document the specific purposes for which they collect personal information. Here is a breakdown of the CPRA’s expectation of data minimisation.

Reasonably necessary 

Companies cannot collect consumer data beyond what is necessary for the disclosed purpose. This means businesses must:

• Clearly communicate the purpose of collection in their privacy policies.
• Avoid excessive data collection that is unrelated to the primary business purpose.
• Ensure that third-party vendors or processors adhere to the same principles.

Proportionality principle

CPRA’s proportionality principle ensures that businesses do not collect more data than is required to fulfil the specified purposes of processing. This involves:

• Conducting regular audits to assess data relevance.
• Implementing consent management tools to regulate data intake.
• Restricting unnecessary fields in data collection forms.

Storage limitation

Under CPRA, businesses cannot retain personal information for longer than necessary. To comply, businesses must:

• Establish clear data retention policies that align with the nature of the business.
• Implement automated deletion schedules.
• Regularly review stored data and remove outdated or irrelevant information.

Step #1: Conduct a data inventory and mapping exercise

Identify what personal information your business collects, where it is stored, how it is processed, and who has access to it. A detailed data map helps ensure compliance by pinpointing areas where excessive information is being collected or retained.

If your organisation handles large amounts of personal information, consider using automated tools to conduct such audits. You may also anonymise personal data wherever possible to reduce data breach risks.

Step #2: Define and document data collection purposes

Update privacy policies and internal documentation to ensure transparency about data collection purposes. Businesses should align their practices with CPRA’s requirements by limiting the processing activities to disclosed and necessary purposes.

Step #3: Implement consent management solutions

Using a robust Consent Management Platform (CMP) enables businesses to control data collection while giving users the ability to manage their preferences. This aligns with CPRA rules and enhances user trust.

Step #4: Establish data retention and deletion policies

Develop a retention schedule that defines the time for which each category of data will be stored in your database. Regularly review it to ensure compliance with CPRA’s proportionality principle.

Businesses may also implement automated data deletion schedules to prevent unnecessary storage of personal data. However, make sure that they are adequately supervised to prevent unexpected data loss.

Step #5: Conduct regular compliance audits

Periodic internal audits help businesses stay compliant by identifying gaps in data minimisation practices. These audits should evaluate:

• Whether the collected data is essential for business operations.
• How long it is being retained.
• Whether it is reasonably necessary and proportionate to fulfil the specific purpose of collection.
• If vendors and third parties follow CPRA’s data minimisation guidelines.

Even with the best intentions, businesses may make errors when implementing data minimisation strategies. The following are some of the common mistakes:

• Over-collecting: Many businesses gather more data than necessary, often due to outdated processes or a lack of clear policies.
• Failing to update retention policies: Without periodic reviews, businesses may store data for longer than required, increasing regulatory risks.
• Inadequate data mapping: Poor visibility into data flows can lead to non-compliance, making it difficult to track and limit data collection.
• Ignoring third-party compliance: Businesses may focus on their internal processes while overlooking whether vendors and partners adhere to CPRA requirements.
• Lack of employee training: Staff may inadvertently collect or retain excess data if they are not properly trained on CPRA’s principles.

Data minimisation—collecting only what’s necessary and retaining it for the shortest time possible—presents unique challenges, especially in a digital-first world. From staying updated on regulatory changes to managing third-party vendors and implementing automated compliance solutions, here’s how businesses can navigate the challenges effectively.

Ensuring compliance with evolving regulations

CPRA enforcement is expected to evolve, making it vital for businesses to stay updated on regulatory changes. Regular training and compliance reviews help mitigate risks. 

Here are some of the ways to keep you ahead of the evolving regulations:

• Subscribe to privacy newsletters
• Follow privacy experts and industry associations on social media
• Regularly review government and regulatory sites for compliance updates
• Participate in compliance training sessions to stay informed on best practices.
• Adopt privacy compliance software that provides real-time alerts on regulatory changes

Managing data across multiple vendors

Businesses often share customer data with third parties or service providers, making it crucial to ensure vendors follow the same data minimisation principles as you. 

Implementing Data Processing Agreements (DPAs) and conducting vendor assessments can help.

Balancing business needs with privacy obligations

Ensure that your company strikes a balance between collecting enough data for operational efficiency and complying with CPRA’s restrictions. Anonymisation and aggregation can help businesses derive insights while minimising privacy risks.

Implementing automated compliance solutions

Manually monitoring data collection and retention can be challenging, especially for large companies. Such businesses may leverage automated tools to enforce minimisation principle, track compliance, and generate audit reports efficiently.