Artifact GuideUSDo not sell or share

US CCPA Do not sell or share

Do not sell or share decisions under the US CCPA should be written in operational language: who is in scope, what must happen, what evidence proves it, and when escalation is needed.

This guide converts official requirements into scope, evidence, ownership, and review decisions for practical implementation, supporting implementation planning and should be validated against jurisdiction-specific legal, contractual, and policy requirements before implementation.

Author
Sorena AI
Published
May 9, 2026
Updated
May 9, 2026
Sections
5

Structured answer sets in this page tree.

Primary sources
5

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated May 9, 2026
Overview

Under the CCPA, California consumers can tell a business to stop selling or sharing their personal information, and the business has to honor that choice. This page first explains what that right actually means, then maps the obligation to trigger conditions, accountable owners, required deadlines, evidence records, and review paths that product, legal, privacy, security, and compliance teams can apply.

Section 1

What does "do not sell or share" actually mean?

The CCPA gives a consumer the right to direct a business to stop selling or sharing their personal information. "Sell" means disclosing a consumer's personal information to a third party for monetary or other valuable consideration. "Share" is narrower and specific to advertising: it means disclosing personal information to a third party for cross-context behavioral advertising, whether or not any money changes hands. A common example of sharing is letting an ad-tech vendor use a site visitor's identifiers to target ads across other sites and apps.

In practice, a business that sells or shares personal information must give consumers a clear way to opt out, most commonly a "Do Not Sell or Share My Personal Information" link, and must treat an opt-out preference signal such as Global Privacy Control as a valid opt-out request. Once a consumer opts out, the business must stop selling or sharing that person's personal information and must pass the opt-out on to third parties it had already sold or shared the information with. A consumer can also authorize someone else to opt out on their behalf.

  • Opt out applies to two things: selling personal information for value, and sharing it for cross-context behavioral advertising.
  • If the business sells or shares, it must offer an opt-out link and honor opt-out preference signals like Global Privacy Control.
  • After an opt-out, stop selling or sharing that consumer's data and tell downstream recipients to do the same.
  • If the business does not sell or share personal information at all, it has no opt-out link duty but should be able to show why the right does not apply.
Section 2

What should teams decide about Do not sell or share under the US CCPA?

Start by deciding whether the issue affects business-threshold status, notice at collection, privacy policy disclosures, consumer rights, do-not-sell/share controls, GPC, service-provider restrictions, or enforcement exposure. The useful answer should name the exact trigger, affected product or process, required action, owner, evidence, and escalation point.

Keep the California source, threshold calculation, notice text, consumer-right workflow, opt-out/GPC evidence, and service-provider contract record together so the CCPA decision can be reviewed later.

  • Define the exact Do not sell or share trigger and the business process it affects.
  • Record which role, product, system, customer group, or data flow is in scope.
  • Attach the source-linked rule, the owner, and the evidence field before approving the control.
  • Escalate uncertainty when the facts depend on thresholds, exemptions, cross-border activity, vulnerable users, or enforcement-sensitive wording.
Section 3

Who should own Do not sell or share, and what evidence should prove the decision?

Ownership should sit with the team that can change notices, request intake, ad-tech settings, vendor contracts, data retention, or consumer-facing controls, with privacy/legal review for ambiguous cases.

Evidence should show threshold calculations, notice-at-collection placement, privacy-policy disclosures, rights request logs, opt-out/GPC handling, vendor restrictions, and enforcement-response readiness.

  • Name one accountable owner and one reviewer for the Do not sell or share workflow.
  • Keep source screenshots or source links, decision notes, implementation tickets, and approval records together.
  • Use dated evidence for deadlines, notices, risk assessments, contracts, user journeys, and regulator-facing records.
  • Review the evidence after product changes, new markets, new vendors, enforcement updates, or material changes in the source text.
Section 4

Which edge cases should teams check before relying on a Do not sell or share decision?

Most CCPA mistakes happen at the boundary between a business, service provider, contractor and third party, or between selling, sharing, financial incentives, minors, GPC, and data-broker obligations.

Apply this section before launching a collection point, ad-tech flow, rights workflow, vendor onboarding, financial incentive, minor-focused journey, or data-broker process.

  • Check whether the rule changes for minors, consumers, business users, public-sector bodies, regulated sectors, high-risk services, or cross-border transfers.
  • Separate binding law, regulator guidance, consultation material, standards, and enforcement commentary in the evidence record.
  • Do not rely on a previous answer if the data categories, user interface, vendor role, or contractual flow changed.
  • Track unresolved assumptions in an open-questions section and route legal interpretation points for review.
Section 5

How should teams operationalize Do not sell or share with proportionate controls?

Use a CCPA workflow that captures threshold status, data category, collection point, consumer right, opt-out or GPC trigger, vendor role, evidence, owner, and review date.

The output should be a threshold note, notice update, DSAR decision, opt-out/GPC record, vendor clause map, dark-pattern review, or enforcement evidence pack.

  • Create a short intake question that identifies the Do not sell or share scenario.
  • Map the answer to a required action, evidence field, owner, reviewer, and review date.
  • Link related artifact pages with descriptive anchors so users can move from scope to deadlines, controls, penalties, and templates.
  • Update the workflow when official source material changes or when internal evidence shows recurring exceptions.
Primary sources

References and citations

leginfo.legislature.ca.gov
Referenced sections
  • California statutory source for operationalizing do-not-sell-or-share links and opt-out preference signal handling.
"Do Not Sell or Share My Personal Information"
iabtechlab.com
Referenced sections
  • Boundary and edge-case support for this artifact page.
"Privacy User Signal Mechanism ("USP API") (CCPA Compliance Mechanism) produced by IAB Technology Laboratory (IAB Tech Lab)"
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