What evidence do auditors commonly ask for on 1798.105(c) Delete on a verified request and pass deletion on?

Deletion procedure covering production systems, analytics stores and service provider copies; Deletion instructions sent to service providers, contractors and third parties with confirmations; Register of retention exceptions applied, with the legal basis for each kept data set; Suppression list used to prevent re-collection or re-sale.

What is the most common gap auditors find on 1798.105(c)?

Data deleted from the main database but left in marketing or analytics platforms

CCPA/CPRA · Requests to know, delete and correct

`1798.105(c)` Delete on a verified request and pass deletion on

On a verifiable deletion request a business must remove the consumer's personal information collected from that consumer, direct each service provider and contractor to erase it, and tell every third party that bought or received it to delete it unless that is impossible or involves disproportionate effort. The business may keep the data where one of the listed exceptions applies, such as completing the transaction, security and integrity, debugging, legal obligations, or internal uses aligned with the consumer's expectations, and may keep a confidential record of the request to prevent re-sale.

Source: CCPA/CPRA, 1798.105(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

none for this control

governing documentDocuments that govern the control

Deletion procedure covering production systems, analytics stores and service provider copies · Policy repository / GRC workspace
Deletion instructions sent to service providers, contractors and third parties with confirmations · Vendor register / contract repository
Register of retention exceptions applied, with the legal basis for each kept data set · Policy repository / GRC workspace
Suppression list used to prevent re-collection or re-sale · Document repository

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

Data deleted from the main database but left in marketing or analytics platforms
Third parties that received the data never told about the deletion

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(e) Maintain reasonable security for personal information · 1798.106(c) Correct inaccurate personal information