What evidence do auditors commonly ask for on 1798.100(e) Maintain reasonable security for personal information?

Written information security policy and risk assessment covering systems that hold personal information; Encryption and redaction standards with evidence of coverage for stored and transmitted personal information; Access control reviews, vulnerability management records and penetration test reports; Incident response plan and breach notification records under Civil Code 1798.82.

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

Personal information held unencrypted in backups, exports or test environments

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

`1798.100(e)` Maintain reasonable security for personal information

A business that collects personal information must run security procedures and practices suited to the nature of the data, so that it is not accessed, destroyed, used, altered or disclosed without authority or unlawfully, as section 1798.81.5 requires. A breach of nonencrypted or nonredacted data caused by a failure of this duty exposes the business to consumer suits for statutory damages under section 1798.150, and putting security in place after a breach does not count as a cure.

Source: CCPA/CPRA, 1798.100(e). 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

moderate

to go live

Vulnerability scanner / patch tooling

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

Access control reviews, vulnerability management records and penetration test reports · Vulnerability scanner / patch tooling

periodic reviewEvidence produced at each review

Written information security policy and risk assessment covering systems that hold personal information · Policy repository / GRC workspace

governing documentDocuments that govern the control

Encryption and redaction standards with evidence of coverage for stored and transmitted personal information · Policy repository / GRC workspace
Incident response plan and breach notification records under Civil Code 1798.82 · Policy repository / GRC workspace

First move

Start with the 1 of 4 artefacts that already live in a system (Vulnerability scanner / patch tooling); keep the periodic reviews but log each one as a dated record with a named reviewer.

Common gaps auditors find

Personal information held unencrypted in backups, exports or test environments
No evidence linking security controls to the sensitivity of the data held

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(d) Put an agreement in place with every recipient of personal information · 1798.105(c) Delete on a verified request and pass deletion on