What evidence do auditors commonly ask for on CCR 7221 Offer an opt-out of ADMT, or a qualifying human appeal?

Opt-out of ADMT form and request log with effective dates; Human appeal procedure, reviewer training and authority to change decisions; Testing evidence that hiring or allocation tools work as intended and do not discriminate where that exception is used; Notifications to processors after an ADMT opt-out.

What is the most common gap auditors find on CCR 7221?

Human reviewer rubber-stamps the output without authority or understanding

CCPA/CPRA · Automated decisionmaking technology (11 CCR Article 11)

`CCR 7221` Offer an opt-out of ADMT, or a qualifying human appeal

From the Article 11 date (1 January 2027 for existing uses), a business using ADMT for a significant decision must let consumers opt out, through two or more methods including an online form linked from the pre-use notice where it deals online, without verification or account creation. It need not offer the opt-out if it provides an appeal to a human reviewer who understands the output and can overturn the decision, or, for admission, hiring and work allocation or pay decisions, if the tool is used only for that assessment and works as intended without unlawful discrimination. An opt-out received before processing begins blocks it; one received later must take effect within 15 business days, with service providers and others processing for the business told to comply in the same time. Re-consent may not be sought for 12 months.

Source: CCPA/CPRA, CCR 7221. 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

moderate

to go live

SIEM / log platform

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

Opt-out of ADMT form and request log with effective dates · SIEM / log platform

periodic reviewEvidence produced at each review

Testing evidence that hiring or allocation tools work as intended and do not discriminate where that exception is used · Document repository
Notifications to processors after an ADMT opt-out · Regulator portal / correspondence

governing documentDocuments that govern the control

Human appeal procedure, reviewer training and authority to change decisions · HR system / LMS

First move

Start with the 1 of 4 artefacts that already live in a system (SIEM / log platform); keep the periodic reviews but log each one as a dated record with a named reviewer.

Common gaps auditors find

Human reviewer rubber-stamps the output without authority or understanding
Exception claimed without any bias or validity testing

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 7220 Give a pre-use notice before using ADMT for significant decisions · CCR 7222 Answer requests to access ADMT information