What evidence do auditors commonly ask for on CCR 7122 Use a qualified, objective and independent auditor working from evidence?

Auditor qualifications and independence declaration; Organisation chart showing the internal audit reporting line; Audit workpapers evidencing testing and sampling; Records retention rule keeping audit documents five years.

What is the most common gap auditors find on CCR 7122?

Internal team that built the controls also auditing them

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

`CCR 7122` Use a qualified, objective and independent auditor working from evidence

The audit must be done by a qualified, objective, independent professional following accepted auditing standards (for example from AICPA, PCAOB, ISACA or ISO). An internal auditor must not design, run or advise on the programme being audited, and the head auditor must report to, be evaluated by and be paid by an executive without direct responsibility for cybersecurity. The business must give the auditor all requested information, disclose relevant facts in good faith, and accept that findings rest mainly on documents, sampling, testing and interviews rather than management assertions. The report goes to the executive responsible for cybersecurity, and both business and auditor keep audit records for five years.

Source: CCPA/CPRA, CCR 7122. 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

Records retention rule keeping audit documents five years · Data governance / DLP tooling

governing documentDocuments that govern the control

Auditor qualifications and independence declaration · Policy repository / GRC workspace
Organisation chart showing the internal audit reporting line · Policy repository / GRC workspace
Audit workpapers evidencing testing and sampling · 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

Internal team that built the controls also auditing them
Findings based on management questionnaires only

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 7121 Meet the cybersecurity audit timetable · CCR 7123 Scope the audit across the 18 programme components and report fully