EvidenceSheet
CCPA/CPRA · Cybersecurity audits (11 CCR Article 9)

CCR 7120 Complete a cybersecurity audit where processing poses significant security risk

A business must complete an annual cybersecurity audit if, in the preceding calendar year, it earned half or more of its revenue from selling or sharing personal information, or it met the revenue threshold of section 1798.140(d)(1)(A) and processed the personal information of at least 250,000 consumers or households or the sensitive personal information of at least 50,000 consumers. First audit reports are due by revenue tier: 1 April 2028 for businesses with more than USD 100 million gross revenue (covering calendar 2027), 1 April 2029 for USD 50 to 100 million, and 1 April 2030 for under USD 50 million (7121).

Source: CCPA/CPRA, CCR 7120. 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).

3
artefacts
0
held by a system
2
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

  • Annual applicability assessment against the 7120(b) tests with revenue and volume figures · Policy repository / GRC workspace
  • Board or executive minute assigning ownership of the audit · Policy repository / GRC workspace

governing documentDocuments that govern the control

  • Determination of the business's revenue tier and first audit deadline · 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

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.

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CCR 7102 Publish annual request metrics if handling data of 10 million or more consumers · CCR 7121 Meet the cybersecurity audit timetable