What evidence do auditors commonly ask for on CCR 7022 Carry out deletion requests completely and explain any denial?

Deletion runbook covering erasure, deidentification or aggregation and backup handling; Responses to consumers confirming deletion or explaining denials with the exemption relied on; Evidence of the opt-out offer made in denial letters where the business sells or shares data.

What is the most common gap auditors find on CCR 7022?

Backups restored without re-applying deletions

CCPA/CPRA · Requests to know, delete and correct

`CCR 7022` Carry out deletion requests completely and explain any denial

Deleting means permanently erasing the data from active systems (backups may wait until next accessed or used), deidentifying it, or aggregating it, and notifying service providers, contractors and third parties as the statute requires. The business tells the consumer whether it complied and that a record of the request is kept. Where it refuses in whole or part, it explains the legal basis, deletes the rest, and if it sells or shares data it asks whether the consumer wants to opt out. It may offer deletion of selected portions only if a single option to delete everything is also offered.

Source: CCPA/CPRA, CCR 7022. 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

Evidence of the opt-out offer made in denial letters where the business sells or shares data · Document repository

governing documentDocuments that govern the control

Deletion runbook covering erasure, deidentification or aggregation and backup handling · Policy repository / GRC workspace
Responses to consumers confirming deletion or explaining denials with the exemption relied on · 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

Backups restored without re-applying deletions
Denials that cite no legal basis

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

CCR 7021 Confirm receipt within 10 business days and respond within 45 calendar days · CCR 7023 Assess and handle correction requests, documentation and denials