What evidence do auditors commonly ask for on 1798.100(c) Keep collection and use necessary and proportionate?

Data minimisation review per processing activity recording the purpose and why each data element is needed; Retention and deletion jobs with run logs showing data removed when its purpose ends; Design review or privacy-by-design checklist completed for new products and features.

What is the most common gap auditors find on 1798.100(c)?

Fields collected because they might be useful later

CCPA/CPRA · General duties: notice at collection, purpose limitation and security

`1798.100(c)` Keep collection and use necessary and proportionate

Gathering, using, keeping and passing on a consumer's data must go no further than needed, and in proportion, for the purpose it was gathered for, or for another disclosed purpose that fits the context of collection. Processing that drifts into purposes incompatible with those is not allowed.

Source: CCPA/CPRA, 1798.100(c). The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open CCPA/CPRA in the compliance library.

Applies only to a business that meets one of the thresholds in Cal. Civ. Code 1798.140(d).

artefacts

held by a system

at each review

hard

to go live

Policy repository / GRC workspace

where the evidence lives

teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

none for this control

periodic reviewEvidence produced at each review

Data minimisation review per processing activity recording the purpose and why each data element is needed · Document repository

governing documentDocuments that govern the control

Retention and deletion jobs with run logs showing data removed when its purpose ends · Policy repository / GRC workspace
Design review or privacy-by-design checklist completed for new products and features · Policy repository / GRC workspace

First move

No system holds this evidence for you: it is people and documents. Reminders and routing to the owner still save time. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date.

Common gaps auditors find

Fields collected because they might be useful later
No documented review of whether retained data still serves a disclosed purpose

Do this for your whole sheet

Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.

Build my evidence sheet

1798.100(a) Inform consumers at or before collection · 1798.100(d) Put an agreement in place with every recipient of personal information