Did you know that the GDPR can impose fines of up to 4% of annual global revenue or €20 million? This regulation, considered the strictest in the world in terms of data protection, has forever changed how companies handle their customers’ personal information.
The protection of personal data is now a critical priority for businesses of all sizes. The General Data Protection Regulation came into force on May 25, 2018, completely redefining the digital privacy landscape. In parallel, the California Consumer Privacy Act (CCPA) began its implementation on January 1, 2020, establishing specific obligations for Californian business entities with revenues in excess of $25 million annually. Subsequently, the California Rights Privacy Act of 2020 further strengthened these provisions.
Although these regulations give consumers greater rights over their data, the consequences of non-compliance differ considerably. While the GDPR can impose penalties of up to $20 million, the CCPA establishes fines of $7,500 for each intentional violation and $2,500 for unintentional violations.
In this practical guide, you’ll learn all the essentials about these three fundamental regulations: the European GDPR, the UK GDPR, and the Californian CCPA. We’ll show you their similarities, key differences, and most importantly, how to ensure your business meets these requirements to avoid costly penalties. Remember that understanding these regulations is not optional – it’s a business necessity that can protect both your finances and your reputation.
Definition and scope of GDPR, UK GDPR, and CCPA
Data protection regulations have transformed the global business landscape with specific regulatory frameworks that, although different, converge on a common goal: to protect the privacy and personal data of citizens.
What is the GDPR and who does it apply to?
The General Data Protection Regulation represents the strictest regulatory framework for data privacy and security globally. Since its entry into force on May 25, 2018, it establishes the rules to ensure the lawful and fair processing of personal data within the European Union.
Here’s who this regulation specifically applies to:
- Any company or entity that processes personal data as part of the activities of its branches established in the EU, no matter where the data is physically processed
- Companies established outside the EU that offer goods or services (free or paid) to individuals in the EU or monitor their behaviour
Remember that the GDPR has extraterritorial reach, affecting global organizations that process data of European residents. Its primary purpose is to empower individuals by granting them control over their personal data while establishing clear guidelines for organizations.
Differences between GDPR and UK GDPR after Brexit
Following Britain’s exit from the European Union, the UK incorporated the European GDPR into its national legislation with minor modifications, creating the UK GDPR. This British version began its application on January 1, 2021.
While the UK GDPR retains the fundamental principles of the European GDPR, we recommend that you be aware of these key differences:
Territorial scope: The European GDPR applies to all member states, while the UK GDPR is specifically limited to the United Kingdom (England, Scotland, Wales, and Northern Ireland).
Supervising Authority: The European GDPR has national data protection authorities coordinated by the European Data Protection Board (EDPB), while the UK GDPR has the Information Commissioner’s Office (ICO) as its sole supervisory authority.
Economic sanctions: The European GDPR allows fines of up to €20 million or 4% of annual global turnover, while the UK GDPR sets maximum fines of £17.5 million or 4% of annual global turnover.
What is the CCPA and how does it relate to the GDPR?
The California Consumer Privacy Act (CCPA) is a state regulation specifically designed to protect the personal data of California residents. Since its entry into force on January 1, 2020, it grants residents specific privacy rights and greater transparency about the business handling of their data.
The CCPA applies only to for-profit businesses operating in California that meet at least one of these criteria: annual gross receipts in excess of $25 million, buying/receiving/selling personal information from 100,000 or more California residents, or deriving 50% or more of their annual revenue from the sale of personal information of California residents.
The fundamental differences between GDPR and CCPA include:
- Consent approach: The GDPR requires explicit prior consent, while the CCPA relies on the subsequent right to opt-out
- Definition of personal data: The GDPR defines personal data as any information relating to an identifiable individual, while the CCPA expands this definition to include browsing history and purchasing behavior
- Penalties for non-compliance: GDPR fines can reach €20 million, while the CCPA establishes fines of up to $7,500 for intentional violations
Compliance with these regulations is essential for any organization that handles personal data of European or Californian citizens, as non-compliance can have serious financial and reputational consequences.
Legal Comparison Between GDPR, UK GDPR, and CCPA
The legal differences between these regulations determine how you should structure your data handling processes. Understanding these fundamentals will allow you to implement compliance strategies that actually work in practice.
Legal basis for processing personal data
The European GDPR provides you with six specific legal bases for processing personal data: consent of the data subject, performance of a contract, compliance with a legal obligation, protection of vital interests, public interest or exercise of public authority, and the legitimate interests of the controller.
The UK GDPR maintains exactly these same six legal bases, preserving the structure of the European GDPR with minor adaptations to the British context.
The CCPA works completely differently. It does not clearly define when or how you may use personal data, and generally does not require a prior legal basis for collecting it, as long as you offer the possibility of opting out. It allows the use of personal information for “business purposes” including auditing, security, and debugging.
Prior Consent vs Right to Opt Out
Here you will find the most practical difference between these regulations. The GDPR consent model requires your explicit consent before collecting any personal data – it’s the famous “opt-in” model. This consent must be free, specific, informed and unambiguous, manifested through a clear affirmative statement or action.
The CCPA takes the opposite approach with its “opt-out” model. It allows you to collect data by default in most cases, except for sensitive or minor data. Consumers can subsequently opt out of the sale of their personal information, but you don’t need prior consent.
International Data Transfers: SCC Clauses and Adequacy Decisions
If you need to transfer data outside of the European Economic Area, the GDPR imposes strict restrictions. You can only do this through appropriate adequacy decisions or guarantees.
The European Commission has recognized as countries with adequate protection: Andorra, Argentina, Canada (trade organizations), Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Republic of Korea, Switzerland, United Kingdom and the United States (commercial organizations participating in the EU-US Data Privacy Framework).
When there is no adequacy decision, you can use standard contractual clauses (SCCs), binding corporate rules (BCRs), codes of conduct or certification mechanisms. These tools ensure that personal data maintains a high level of protection when transferred outside the EEA.
The UK GDPR follows similar approaches for international transfers, while the CCPA does not impose specific requirements for these transfers. This difference can significantly simplify your operations if you only handle Californian data.
User rights under each regulation
All three regulations guarantee specific protections for personal data, although with important differences in their practical application. Knowing these rights will allow you to implement the proper procedures in your company.
Right of access, rectification and deletion
What exactly can users request? The right of access allows anyone to obtain confirmation as to whether their data is being processed and to receive a full copy of that information. Both the GDPR and the UK GDPR set out this right in Article 15, granting users access not only to their data but also to the purpose of processing, categories of data, recipients and intended retention periods.
The right to rectification, provided for in Article 16 of both European regulations, allows inaccurate data to be corrected or incomplete information to be completed. This right connects directly with the principle of accuracy required by Article 5(1)(d) of the GDPR.
Regarding the right to erasure or “right to be forgotten”, Article 17 of the GDPR establishes when users can request the deletion of their personal data. This includes situations where the data is no longer needed, when consent is withdrawn, or when the processing is unlawful.
The CCPA provides for similar rights but with different deadlines: companies have 45 days to respond to these requests, which can be extended by an additional 45 days by notifying the consumer.
Right to data portability
Article 20 of the GDPR introduces a key right: to request a copy of personal data in structured, commonly used and machine-readable format. However, this right only applies where the processing is based on consent or contract.
Portability seeks to give users real control of their data, allowing them to transfer it between different services without technical obstacles. Remember that this right facilitates competition between digital service providers.
Right not to be discriminated against for exercising privacy rights
The CCPA specifically provides this protection, prohibiting businesses from discriminating against consumers for exercising their privacy rights. This means that you cannot deny goods or services, charge different prices, provide different quality, or suggest differentiated rates.
Unlike other anti-discrimination laws, the CCPA extends this protection to all California consumers who exercise any of their rights, not limited to specific protected categories. We recommend that you implement clear processes to address these requests without penalizing users who make them.
Business obligations and penalties for non-compliance
Companies that process personal data must comply with specific obligations under these regulations. Failure to comply can result in devastating financial penalties for your business.
Technical and organisational measures required by the GDPR
The GDPR requires you to implement appropriate technical and organizational measures that ensure a level of security appropriate to the risk of your operations. These measures include:
- Pseudonymization and encryption of personal data
- Ensuring system confidentiality, integrity, and availability
- Ability to restore access to data after physical or technical incidents
- Process of regular evaluation of the effectiveness of the measures implemented
For high-risk processing, you must carry out a Data Protection Impact Assessment (DPIA). In addition, we recommend that you raise awareness among your staff through regular training and meticulously document all safety procedures.
GDPR fines: up to €20 million or 4% of revenue
The GDPR sanctioning regime operates on two clearly differentiated levels:
- Less serious infringements: fines of up to €10 million or 2% of annual global turnover
- Serious infringements: fines of up to €20 million or 4% of annual global turnover
Authorities determine penalties by considering multiple factors: nature of the violation, intentionality, mitigation measures taken, prior history of compliance, and cooperation with supervisory authorities.
CCPA penalties: up to $7,500 per willful violation
CCPA penalties, while seemingly minor, can add up quickly and lead to significant costs:
- Unintentional violations: up to $2,541.06 per violation
- Willful violations: up to $7,622.23 per violation
- Violations involving child data: up to $7,622.23 per case
From 2025, these amounts are adjusted according to the Consumer Price Index. The critical thing is that these fines are applied per individual violation and per affected consumer, which means that a company with thousands of customers can face millions of dollars for a single incident.
Practical compliance and recommended tools
Effective implementation of privacy regulations requires specific tools that facilitate both technical and organizational compliance. Below, we’ll show you how to choose the right solutions for your business.
Where can I hire an email verification service with GDPR compliance?
To find the right provider, it is essential to choose a company that has designed its technology from the ground up under data protection principles. Verificaremails.com applies privacy by design and privacy by default to ensure compliance with the European GDPR, the UK GDPR, and the California CCPA/CPRA across all of its services.
This approach means that data is processed solely for technical purposes, without reuse, without external enrichment, and without transfers to third parties. Remember that these principles of minimisation and purpose limitation are essential to comply with international data protection regulations.
Regulatory compliance in verifying emails, phones and other contact details
We recommend that you look for suppliers that translate regulatory compliance into concrete and verifiable measures. The verification of emails and phone numbers must be done in real time without permanent storage of the data. Bulk verification files are retained only for limited periods and are automatically deleted.
All processing infrastructure must be managed under strict security controls. This approach allows companies and professionals to hire verification services with the peace of mind of complying with both European regulations and the most relevant international regulatory frameworks, reducing legal risks and ensuring responsible management of personal data.
Use Case: How to Verify Emails GDPR and CCPA Compliant
VerifyEmails stands out for physically locating its servers in the European Union, thus avoiding international data transfers. It implements encryption on all data uploaded to the platform and protects communications using https.
Its real-time API allows you to validate emails without the need to store personal data on your servers. Data can be deleted at any time, giving the user full control over the processed information. On a contractual level, it clearly defines the ownership of data and access by the VerificarEmails team.
If you need to verify emails in compliance with these regulations, our support team will be happy to help you with the technical implementation and resolution of specific compliance questions.
Conclusion
Once you’ve reviewed the main features of these three regulations, you’ll understand that compliance requires more than knowing the theoretical differences: you need to implement practical measures that protect both your company and your customers.
Remember that differences in consent models directly affect how you should design your data collection processes. If your company operates in multiple jurisdictions, we recommend adopting the highest standard as a baseline, as this will allow you to simultaneously comply with all regulations.
The rights granted to users under these regulations require you to implement effective technical and organizational mechanisms. This includes clear procedures for responding to requests for access, rectification or deletion, as well as systems that facilitate data portability when necessary.
Did you know that data protection can become a competitive advantage? Companies that demonstrate a genuine commitment to privacy often strengthen their reputation and build greater trust with their customers in the long run.
To verify emails in compliance with these regulations, tools such as Verifyemails offer solutions designed from the ground up under the principles of “privacy by design” and “privacy by default”. Its servers located in the European Union prevent international data transfers, while its real-time API allows you to validate addresses without permanent storage of personal information.
If you have any questions about compliance with these regulations in your fact-checking processes, our support team will be happy to help you implement best practices for your specific case.
The key to success lies in seeing these regulations not as obstacles, but as opportunities to build stronger relationships with your customers based on transparency and respect for their privacy.
Key Takeaways
Here are the essential keys to understanding and complying with the key data protection regulations that affect global enterprises:
• The GDPR can impose fines of up to $20 million or 4% of global revenue, while the CCPA establishes penalties of $7,500 for intentional infringement that accrue for each affected consumer.
• The GDPR requires explicit prior consent (opt-in) to process data, while the CCPA allows for collection by default with a subsequent right to opt-out.
• All three regulations grant similar rights of access, rectification, and deletion, but the CCPA specifically adds the right not to be discriminated against for exercising privacy rights.
• To effectively comply, it implements the most demanding standard (GDPR) as a foundation, as this ensures simultaneous compliance with multiple jurisdictions.
• Use tools with “privacy by design” that process data only for technical purposes, without permanent storage or transfers to third parties, especially for verification of emails and contact details.
Compliance with these regulations not only avoids costly penalties, but also builds trust with customers and strengthens business reputation in the long run. The key is to take a proactive approach that sees data protection as a competitive advantage, not just a legal obligation.
FAQs
Q1. What are the main differences between GDPR and CCPA? While the GDPR requires prior explicit consent (opt-in) to process data, the CCPA allows for collection by default with a subsequent right to opt-out. In addition, GDPR fines can reach $20 million or 4% of global revenue, while the CCPA establishes penalties of up to $7,500 per intentional violation per affected consumer.
Q2. What rights do these regulations grant users over their personal data? Both the GDPR and the CCPA guarantee rights of access, rectification, and deletion of personal data. Additionally, the GDPR includes the right to data portability, while the CCPA specifically adds the right not to be discriminated against for exercising privacy rights.
Q3. How does Brexit affect data protection in the UK? After Brexit, the UK adopted the UK GDPR, which maintains the fundamental principles of the EU GDPR but with some modifications to adapt it to the British context. The main supervisory authority in the UK is now the Information Commissioner’s Office (ICO).
Q4. What measures should companies implement to comply with these regulations? Companies must implement appropriate technical and organizational measures, such as pseudonymization and encryption of data, ensure the confidentiality and integrity of systems, and establish processes to respond to user rights requests. It is also crucial to carry out impact assessments for high-risk processing and train staff on data protection.
Q5. How can companies verify emails in compliance with these data protection regulations? To verify GDPR, UK GDPR, and CCPA compliant emails, companies can use services that apply “privacy by design” and “privacy by default” principles. These services must process the data only for technical purposes, without permanent storage or transfers to third parties, and preferably with servers located in the EU to avoid international data transfers.
