§1798.185(a)(15) Risk Assessments for High-Risk Processing
Businesses whose processing of PI presents significant risk to consumers privacy or security must submit risk assessments to the CPPA on a regular basis. Risk assessments must weigh the benefits to the business, consumer
3
artefacts
0
held by a system
2
at each review
hard
to go live
Data governance / DLP tooling
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
- Submitted assessment to CPPA per cadence · Data governance / DLP tooling
- Risk assessment register · Data governance / DLP tooling
governing documentDocuments that govern the control
- Risk assessment template covering benefits, risks, mitigations, processing purposes, categories of PI, retention, automated decisionmaking · 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
- Risk assessments not conducted for high-risk activities (sensitive PI, training AI, profiling, minors)
- No standardised methodology
- CPPA submission not scheduled
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§1798.155 Administrative Enforcement and Civil Penalties · §1798.185(a)(16) Automated Decisionmaking Technology Access and Opt-Out