Artifact GuideUSDo Not Sell Share Implementation

US CCPA Do Not Sell Share Implementation

Do Not Sell Share Implementation 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
6

Cited legal and guidance references.

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

If a business sells or shares personal information, the CCPA requires it to build a working opt-out: a way for consumers to say no, a way to honor browser opt-out signals, and a process that actually stops the data flow. This page explains what that implementation should include, then maps it to trigger conditions, accountable owners, deadlines, evidence records, and review paths for product, legal, privacy, security, and compliance teams.

Section 1

What does a compliant do-not-sell/share setup include?

A compliant implementation has three parts. First, give consumers a clear opt-out method: businesses that sell or share personal information must post a "Do Not Sell or Share My Personal Information" link (or use an alternative opt-out mechanism that the regulations allow) so a consumer can exercise the right without friction. Second, detect and honor opt-out preference signals: the California Attorney General has confirmed that a Global Privacy Control signal must be honored by covered businesses as a valid consumer opt-out request, so the site must read that signal and treat it as an opt-out for that browser or device.

Third, make the opt-out actually take effect downstream. Once a consumer opts out, the business must stop selling or sharing that consumer's personal information, update its ad-tech tags and audience integrations so identifiers are no longer passed for sale or cross-context behavioral advertising, and notify third parties it previously sold or shared the data to. Disclose the right and the opt-out method in the privacy policy, and keep the design free of dark patterns that steer consumers away from opting out.

  • Opt-out entry point: a "Do Not Sell or Share My Personal Information" link or an equivalent permitted mechanism, reachable before any sale or sharing.
  • Signal handling: detect Global Privacy Control and apply it as a valid opt-out without requiring the consumer to do anything else.
  • Downstream enforcement: suppress sale/sharing tags, update ad-tech and audience integrations, and pass the opt-out to prior recipients.
  • Disclosure and records: describe the right in the privacy policy and log each opt-out, the date applied, and the systems updated.
Section 2

What should teams decide about Do Not Sell Share Implementation under the US CCPA?

Decide first which surface the work touches: business-threshold status, notice at collection, privacy-policy disclosures, the opt-out link, GPC signal handling, service-provider and contractor restrictions, or enforcement exposure. For each item, name the exact trigger, the affected product or process, the required action, the owner, the evidence, and the escalation point so the decision is actionable rather than abstract.

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 Share Implementation 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 Share Implementation, 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 Share Implementation 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 Share Implementation 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 Share Implementation 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, consumer request 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 Share Implementation 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 statute for the opt-out link and opt-out preference signal handling.
"Do Not Sell or Share My Personal Information"
cppa.ca.gov
Referenced sections
  • CPPA consumer FAQ context for CCPA rights and enforcement routes relevant to opt-out implementation evidence.
"You cannot sue businesses for most CCPA violations"
iabtechlab.com
Referenced sections
  • Industry implementation context for replacing legacy US privacy signals; not a substitute for California statute or CPPA guidance.
"The GPP is the only privacy signaling mechanism available to signal consumer privacy choices for all US states"
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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