What evidence do auditors commonly ask for on CCR 7002 Purposes must match reasonable expectations, or consent is needed?

Purpose compatibility assessments recording the expectation factors considered and the conclusion; Consent records (time, wording shown, choice made, withdrawal) for purposes outside the expected ones; Register of processing purposes cross-referenced to the notice at collection.

What is the most common gap auditors find on CCR 7002?

Secondary uses such as model training or data monetisation treated as compatible without analysis

CCPA/CPRA · General duties: notice at collection, purpose limitation and security

`CCR 7002` Purposes must match reasonable expectations, or consent is needed

The regulation gives the test behind section 1798.100(c). A purpose must fit what the consumer would reasonably expect, judged by the relationship, the type and amount of data, its source and collection method, how clearly the purpose was disclosed and how visible any service providers or third parties are. A further purpose is compatible only where it is strongly linked to those expectations. Necessity and proportionality are judged by the minimum data needed, the possible harm to consumers and the safeguards in place. Any purpose that fails the test needs the consumer's consent, obtained in the way section 7004 requires and capable of withdrawal, and collecting categories beyond those in the notice at collection requires a new notice.

Source: CCPA/CPRA, CCR 7002. 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

Purpose compatibility assessments recording the expectation factors considered and the conclusion · Document repository
Consent records (time, wording shown, choice made, withdrawal) for purposes outside the expected ones · Data governance / DLP tooling

governing documentDocuments that govern the control

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

Secondary uses such as model training or data monetisation treated as compatible without analysis
Consent bundled with terms of use, so it cannot be withdrawn separately

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

1798.136 Browsers must offer an opt-out preference signal setting (from 1 January 2027) · CCR 7003 Make disclosures readable, accessible and linked conspicuously