§1798.100 General Duties of Businesses that Collect Personal Information
Businesses collecting personal information about consumers must inform consumers, at or before the point of collection, of the categories of PI collected and the purposes for which categories will be used. PI shall not b
5
artefacts
0
held by a system
0
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
system holds itEvidence a system already holds
none for this control
periodic reviewEvidence produced at each review
none for this control
governing documentDocuments that govern the control
- Notice at collection text on web forms and physical points of collection · Policy repository / GRC workspace
- Privacy policy disclosures of categories and purposes · Policy repository / GRC workspace
- Data inventory mapping categories to purposes and retention periods · Policy repository / GRC workspace
- Information security program documentation · Policy repository / GRC workspace
- Retention schedule with criteria and disposal evidence · Policy repository / GRC workspace
First move
This control is evidenced by people and documents, not systems. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date. Do not try to automate it.
Common gaps auditors find
- No notice at offline collection points
- Purposes described vaguely (e.g. business operations)
- Retention periods absent or stated as indefinite
- Security controls not mapped to PI categories
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 sheetCCR §7301-7304 CPPA Audit and Investigation Cooperation · §1798.100(d) Contractual Requirements for Third Parties, Service Providers, and Contractors