What evidence do auditors commonly ask for on 1798.121 Honour the right to limit use of sensitive personal information?

Register of sensitive personal information uses mapped to the permitted purposes; Limit-request preference store and enforcement in downstream systems; Analysis of whether sensitive data is processed to infer characteristics.

What is the most common gap auditors find on 1798.121?

Precise geolocation used for advertising without offering the right to limit

CCPA/CPRA · Opt-out of sale or sharing, limiting sensitive data and preference signals

`1798.121` Honour the right to limit use of sensitive personal information

A business using or disclosing sensitive data beyond what an average consumer expects for the requested goods or services, or the other purposes the regulations allow (11 CCR 7027(m)), must tell consumers so and let them limit use to those purposes. After a request to limit, the business may use the data only for those purposes unless the consumer later consents. Sensitive data handled with no aim of inferring characteristics about the consumer is treated as ordinary personal information.

Source: CCPA/CPRA, 1798.121. 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

Analysis of whether sensitive data is processed to infer characteristics · Document repository

governing documentDocuments that govern the control

Register of sensitive personal information uses mapped to the permitted purposes · Policy repository / GRC workspace
Limit-request preference store and enforcement in downstream systems · 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

Precise geolocation used for advertising without offering the right to limit
No inventory distinguishing permitted from additional uses

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

1798.120(c) Obtain opt-in before selling or sharing data of consumers under 16 · 1798.125(a) Do not discriminate or retaliate against consumers who use their rights