What evidence do auditors commonly ask for on 1798.135(c) Run opt-out and limit requests without friction or reuse?

Opt-out form showing only the fields needed; Re-consent suppression logic enforcing the 12-month wait; Data handling rule that restricts opt-out request data to processing the request.

What is the most common gap auditors find on 1798.135(c)?

Opt-out form requiring account login

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

`1798.135(c)` Run opt-out and limit requests without friction or reuse

A business subject to section 1798.135 must not demand an account or more information than needed to act on an opt-out or limit request; must describe these rights with the links, or a statement that it honours opt-out preference signals, in its privacy policy; must brief staff who handle privacy enquiries; must stop the sale, sharing or extra use and let 12 months pass before seeking the consumer's agreement to opt back in; must apply the same 12-month wait for minors who declined consent; and may use information collected with the request only to carry it out. Persons to whom an opt-out is passed may then use the data only for the business's specified purpose (1798.135(f)).

Source: CCPA/CPRA, 1798.135(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

moderate

to go live

Cloud console / configuration management

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

Data handling rule that restricts opt-out request data to processing the request · Cloud console / configuration management

periodic reviewEvidence produced at each review

none for this control

governing documentDocuments that govern the control

Opt-out form showing only the fields needed · Document repository
Re-consent suppression logic enforcing the 12-month wait · Policy repository / GRC workspace

First move

Start with the 1 of 3 artefacts that already live in a system (Cloud console / configuration management); keep the periodic reviews but log each one as a dated record with a named reviewer.

Common gaps auditors find

Opt-out form requiring account login
Marketing re-prompting opted-out consumers within weeks

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

1798.135(a) Post the opt-out and limit links, or a single alternative link · 1798.136 Browsers must offer an opt-out preference signal setting (from 1 January 2027)