What evidence do auditors commonly ask for on CCR 7028 Opt back in through a two-step process only?

Opt-in flow screenshots showing the request and the separate confirmation; Consent records showing both steps with timestamps.

What is the most common gap auditors find on CCR 7028?

One-click re-consent prompts presented to opted-out consumers

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

`CCR 7028` Opt back in through a two-step process only

Consent to resume sale, sharing or extra use of sensitive data after an opt-out or limit request needs two separate steps: a clear request to opt in followed by a separate confirmation. If an opted-out consumer starts a transaction that requires selling, sharing or the extra use, the business may explain this and offer the opt-in, following section 7004.

Source: CCPA/CPRA, CCR 7028. 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

Policy repository / GRC workspace

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

Consent records showing both steps with timestamps · Data governance / DLP tooling

governing documentDocuments that govern the control

Opt-in flow screenshots showing the request and the separate confirmation · Policy repository / GRC workspace

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

One-click re-consent prompts presented to opted-out consumers

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 7027 Handle requests to limit use of sensitive personal information · CCR 7050 Service providers and contractors: permitted uses and cooperation