What a Compliant Privacy Policy Actually Requires | Privacy Laws | CCPA

If you’re in a fast-growing company, odds are someone—maybe Legal, maybe Marketing—was told to “get a privacy policy up on the site.” That’s a good first step. But in today’s privacy landscape, simply having a policy isn’t enough.

With new laws, heightened customer expectations, and evolving ad tech rules, your privacy policy needs to do more than simply tick a compliance box. It has to be clear, accurate, and aligned with real backend behavior—or it might actually expose you to risk.

In this post, we’ll break down exactly what a compliant privacy policy needs in 2025, based on today’s regulations and best practices.

Why It Matters

Let’s be blunt: regulators are paying attention, particularly to customer-facing elements like consent management and privacy policies. Enforcement actions are on the rise—not just for Big Tech, but for companies of all sizes. Transcend extensively covered two of these fines, against Honda and against Todd Snyder.

• California AG enforcement examples show companies being fined not because they lacked a privacy policy, but because their policy didn't match their actual practices. (1)
• The California Privacy Protection Agency’s enforcement of the California Privacy Rights Act (CPRA) expanded this year after a hiring spree at the agency, and early audits are focused on notice and user rights. (2)
• International regulators under General Data Protection Regulation (GDPR) have also been continuously issuing fines for vague or incomplete policies. (3)

In short: if your privacy policy is generic, outdated, or disconnected from how your systems actually work, you may be out of compliance—even if you think having a privacy policy means you’re covered.

What Your Privacy Policy Must Include

Here’s a breakdown of the core elements a CCPA-compliant privacy policy must address, with examples to help you write one that holds up.

1. What personal information you collect

This includes:

• Identifiers like name, email, IP address
• Device and browser info
• Geolocation data
• Behavioral data (e.g. what users click or view)

Be specific. Instead of “we collect information you provide,” write:

“We collect your name, email address, and any additional information you include when submitting a contact form.”

2. How you collect it

State whether it’s:

• Provided by the user (e.g. contact forms, newsletter signups)
• Collected automatically (e.g. via cookies, analytics tools)
• Obtained from third parties (e.g. advertising partners)

Example:

“We use cookies and similar technologies to track user activity on our site and collect standard internet log information and behavior patterns.”

3. Why you collect it (purpose of processing)

Explain the business reasons:

• To improve site performance
• To respond to inquiries
• To serve relevant ads
• To comply with legal obligations

Avoid vague language like “to serve you better.” Be concrete.

4. How users can exercise their rights

If you’re subject to GDPR, CCPA/CPRA, or other laws, you must:

• Outline what rights users have (access, delete, correct, etc.)
• Explain how they can exercise those rights (e.g. via a webform or email)

Example:

“California residents have the right to request access to or deletion of their personal information. To submit a request, please visit [link].”

5. Your data retention practices

Tell users how long you keep data and why. If you don’t have a policy yet, you need one.

Example:

“We retain your data only for as long as necessary to fulfill the purpose for which it was collected, or as required by law.”

Additional Requirements Under CPRA & GDPR

CCPA/CPRA-specific requirements:

• Include a “Do Not Sell or Share My Personal Information” link if applicable
• Explain your use of sensitive personal information
• Say whether you use or allow targeted advertising (and how to opt out if so)

GDPR-specific requirements:

• State your legal basis for processing (e.g. consent, contract)
• Include your company’s data controller details and contact info
• Disclose if you transfer data outside the EU

Best Practices Beyond Legal Minimums

Even if you're just trying to stay compliant, the best privacy policies also:

• Use plain language – no legalese
• Match your actual systems
• Get updated at least twice per year
• Include a version date and changelog for transparency
• Link to cookie and preference centers where applicable

Tools and Resources

• California’s CCPA/CPRA Guidelines
• GDPR Quick Guide
• IAPP Privacy Policy Checklist
• FTC Guidelines on Transparency

Final Word

A privacy policy isn't a one-and-done task. It's a living document that needs to evolve with your data practices and the relevant laws. A compliant privacy policy reflects what your company actually does—and protects you from lawsuits, fines, and loss of trust.

If you’re still using a template you found online in 2021, it’s time for an update.

✅ Need help automating privacy workflows so your policy stays accurate? That’s what we do.

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