The California Consumer Privacy Act (CCPA) and its expansion, the California Privacy Rights Act (CPRA), set standards for how digital service providers collect and share the data of customers in the Golden State. Compliance with the CCPA and CPRA is especially important to consider when you select a payment provider, as the fine for each violation can be nearly $8,000.

Below, we’ll explain how to choose a payment vendor that’s CCPA compliant, including how to evaluate vendor privacy capabilities and how to find compliance gaps early in the procurement process.

What’s in this article?

• Why does the California Consumer Privacy Act matter for payments?
  
• What personal data does a payment processor use?
  
• How should you evaluate a vendor’s CCPA compliance?
  
• What signs point to weak data governance in payments?
  
• How can procurement teams structure a request for proposal to spot CCPA compliance gaps early?
  
• How Stripe Payments can help
  

Why does the California Consumer Privacy Act matter for payments?

The CCPA gives Californians the right to know how their personal information is collected, request its deletion, and stop it from being sold. The CCPA’s scope includes payment providers since they handle sensitive data, including names, emails, addresses, card numbers, and transaction details.

Often, payment vendors are considered “service providers” under the law. Businesses can share customer data with payment vendors for limited and specified reasons, and vendors must provide the same level of privacy protection. If a payment processor repurposes that data (e.g., by analyzing transaction histories to build its own marketing products), it steps outside that legal boundary.

Ignoring the CCPA can lead to fines and reputational damage, even if your business is based outside California. The CCPA applies to all California residents, no matter where your business is located—similar to Europe’s General Data Protection Regulation (GDPR).

What personal data does a payment processor use?

Every payment involves a variety of personal and sensitive information.

Here’s what that can include:

• Customer identifiers: Names, emails, postal addresses, and account names. Even internet protocol (IP) addresses gathered during checkout qualify as personal information.

• Financial data: Credit and debit card numbers, expiration dates, security codes, and bank account and routing numbers. The CCPA classifies these as sensitive personal information because they tie directly to financial identity.

• Transaction data: Purchase history, order values, time stamps, and business details. These records reveal spending patterns linked to specific individuals.

• Fraud prevention data: Device fingerprints, geolocation, and behavioral indicators used to detect fraud all count as personal data under the law.

• Authentication data: Encrypted login credentials, account tokens, and sometimes biometric identifiers such as facial or fingerprint verification are considered sensitive data.

• Customer communications: Support emails, chat logs, and call recordings often contain personal details tied to accounts or transactions.

How should you evaluate a vendor’s CCPA compliance?

Payment providers process data on your behalf, but you need to ensure they can support the requests your customers are legally entitled to make.

You should consider the following:

• Consent and opt-out handling: Under the CCPA, many payment providers don’t need opt-in consent to collect data, but they do need to honor “Do Not Sell or Share” preferences. If they rely on cookies or tracking tools for fraud detection or analytics, you should confirm that those don’t conflict with opt-out rights.

• Access and portability: Customers have the right to know what personal data a business holds. That means your vendor must be able to retrieve it on demand. Ask how it locates and compiles individual records (by email, card token, or transaction ID) and how it verifies identity before it releases data. Mature vendors can produce this information via an application programming interface (API) or a defined workflow.

• Deletion and retention controls: Service providers are generally required to delete customer information, if requested. Deleting payment data isn’t always straightforward. Vendors must be able to remove personal data when you instruct them to, while retaining what’s legally necessary for compliance.

What signs point to weak data governance in payments?

Spotting the warning signs of weak data governance can save you from compliance risk and reputational damage later.

Watch for the following:

• No proof of compliance: A mature vendor can show evidence of careful data management. Payment Card Industry Data Security Standard (PCI DSS) reports, documented CCPA procedures, System and Organization Controls (SOC) 2 reports, or International Organization for Standardization (ISO) certifications can provide context.

• Vague security practices: Encryption, access controls, and vulnerability testing should be standard. If a vendor is storing unencrypted card data, lacks multifactor authentication, or can’t describe its breach response plan, that’s a deal-breaker.

• Opaque data use: Some payment providers use transaction data for analytics, advertising, or machine learning models unrelated to your business. They must give customers the choice to opt out of targeted advertising.

• Resistance to transparency: Evasion during due diligence (e.g., avoiding direct answers about data flows, retention, or subprocessors) is a clear warning sign. Other troubling signs include refusing to fill out security questionnaires or allow limited audits.

• No privacy leadership: If the vendor has no privacy officer or compliance team, or no internal training for staff who handle customer data, its risk management might be reactive at best.

How can procurement teams structure a request for proposal to spot CCPA compliance gaps early?

A request for proposal (RFP) for a payment provider can help you compare the data governance maturity of vendors.

Consider taking the following actions:

• Include a dedicated privacy section: Don’t bury data protection in the appendix. Make CCPA compliance its own scored category, signaling that privacy is part of the business criteria, not a side issue.

• Ask for data specifics: Request a clear list of what personal information the vendor collects, processes, and retains, such as names, emails, card data, and device IDs—and why. Compare answers across vendors, with the understanding that extra or unnecessary data collection is a warning sign.

• Investigate customer rights handling: Ask how it processes access and deletion requests, including verification and turnaround times. Strong vendors can explain this step-by-step or provide sample workflows.

• Check data retention and exit procedures: Require vendors to state how long they keep personal data, what triggers deletion, and how they handle data when your contract ends. You want commitments to delete or return data on instruction.

• Evaluate security and transparency: Ask for audit reports (e.g., SOC 2, PCI DSS, ISO/IEC 27001) and written breach notification procedures. Vendors that can’t supply them aren’t ready for enterprise compliance.

How Stripe Payments can help

Stripe Payments provides a unified, global payment solution that helps any business—from scaling startups to global enterprises—accept payments online, in person, and around the world.

Stripe Payments can help you:

• Optimize your checkout experience: Create a frictionless customer experience and save thousands of engineering hours with prebuilt payment UIs, access to 125+ payment methods, and Link, a wallet built by Stripe.

• Expand to new markets faster: Reach customers worldwide and reduce the complexity and cost of multicurrency management with cross-border payment options, available in 195 countries across 135+ currencies.

• Unify payments in person and online: Build a unified commerce experience across online and in-person channels to personalize interactions, reward loyalty, and grow revenue.

• Improve payment performance: Increase revenue with a range of customizable, easy-to-configure payment tools, including no-code fraud protection and advanced capabilities to improve authorization rates.

• Move faster with a flexible, reliable platform for growth: Build on a platform designed to scale with you, with 99.999% historical uptime and industry-leading reliability.

Learn more about how Stripe Payments can power your online and in-person payments, or get started today.