What evidence do auditors commonly ask for on 1798.106(c) Correct inaccurate personal information?

Correction procedure with the steps for assessing disputed data; Records of corrections made across systems and instructions to service providers; Responses to consumers on correction requests.

What is the most common gap auditors find on 1798.106(c)?

Correction made in one system but overwritten by a later data feed

CCPA/CPRA · Requests to know, delete and correct

`1798.106(c)` Correct inaccurate personal information

On a verifiable request a business must use commercially reasonable efforts to correct inaccurate personal information as the consumer directs, considering the nature of the data and why it is processed. Service providers and contractors must help, and the business discloses the correction right in its privacy policy.

Source: CCPA/CPRA, 1798.106(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

Document repository

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

Records of corrections made across systems and instructions to service providers · Document repository

governing documentDocuments that govern the control

Correction procedure with the steps for assessing disputed data · Policy repository / GRC workspace
Responses to consumers on correction requests · 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

Correction made in one system but overwritten by a later data feed

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

1798.105(c) Delete on a verified request and pass deletion on · 1798.110(b) Disclose collected personal information on a verified request