Not necessarily.

Although the CCPA’s definition of “consumer” includes employees that reside in California,1 the CCPA applies only to a “business” -- a term that is defined as being an entity that “does business in the State of California” and that meets one of the following three thresholds:

  1. Annual gross revenue in excess of $25 million,
  2. Purchase, receives for commercial purposes, sells, or shares for commercial purposes, personal information of 50,000 or more consumers, or
  3. Derives 50% of annual revenue from selling consumer personal information.2

The net result is that if a business meets one of the three thresholds established for gross revenue, quantity of data points, or revenue-generated by the sale of personal information, and has California employees, then it will be subject to the CCPA. If a business does not meet one of the three thresholds set forth above, but has California employees, then it will not be subject to the CCPA.