What evidence do auditors commonly ask for on CCR 7150 Conduct a risk assessment before high-risk processing?

Inventory of processing activities screened against the six 7150(b) triggers; Pre-launch gate in the product or procurement process requiring an assessment; List of pre-existing processing activities with assessment completion dates before 31.

What is the most common gap auditors find on CCR 7150?

Advertising sharing not recognised as a trigger

CCPA/CPRA · Risk assessments (11 CCR Article 10)

`CCR 7150` Conduct a risk assessment before high-risk processing

Any business, whatever its size, must carry out a risk assessment before starting processing that the regulation treats as a significant privacy risk: selling or sharing personal information; processing sensitive personal information (other than routine employee administration such as payroll, benefits, work authorisation and legally required accommodation or wage reporting); using ADMT for a significant decision; automated inference about applicants, students, employees or contractors from systematic observation; automated inference from presence at a sensitive location; and processing data intended to train ADMT for significant decisions or facial, emotion or identity recognition technology. The duty applies to processing begun on or after 1 January 2026; processing already under way then must be assessed by 31 December 2027 (7155(b)).

Source: CCPA/CPRA, CCR 7150. 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

none for this control

governing documentDocuments that govern the control

Inventory of processing activities screened against the six 7150(b) triggers · Policy repository / GRC workspace
Pre-launch gate in the product or procurement process requiring an assessment · Policy repository / GRC workspace
List of pre-existing processing activities with assessment completion dates before 31 · 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

Advertising sharing not recognised as a trigger
Employee monitoring analytics launched without an assessment

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 7124 Certify completion of the cybersecurity audit to the CPPA · CCR 7151 Involve the people who run the processing