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Artifact GuideUSDSAR Verification

US CCPA DSAR Verification

Verify identity for delete, correct, know, and access requests using a reasonable method proportionate to the information requested; do not require identity verification for sale or sharing opt-outs, limit requests, or ADMT opt-outs.

For privacy operations, support, identity, and security teams handling consumer requests and authorized agents.

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Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
4 sections2 primary sources
Overview

DSAR means data subject access request, a privacy-operations label rather than a separate CCPA right. Verify requests to know, delete, and correct with a reasonable method matched to the request and risk. Do not require identity verification for a request to opt out of sale or sharing or a request to limit use and disclosure of sensitive personal information. Collect additional identity data only when existing information cannot reasonably verify the request. Article 11 access, appeal, and opt-out duties for significant-decision automated decisionmaking technology (ADMT) require compliance from January 1, 2027.

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Find a question or answer quickly

4 of 4 questions
Question 1

How should verification differ for accounts and non-accountholders?

Start by classifying the right. For a password-protected account, the regulations generally allow verification through the business's existing authentication practices, but the business must reauthenticate the consumer before deleting or correcting data or disclosing the requested data. It must also use reasonable security safeguards.

For a non-accountholder, match data supplied by the consumer against reliable information the business already maintains. A request for categories of personal information requires a ; a request for specific pieces or access to ADMT requires a . A deletion or correction request uses the assurance level appropriate to the sensitivity of the information and risk of harm from unauthorized action.

  • Classify the request before asking for identity information.
  • Use existing account authentication or existing records when reasonably possible.
  • Document the assurance level, matching points, reliability, sensitivity, fraud risk, and consequence of unauthorized action.
  • If verification fails, explain the result and any available way to provide additional information without disclosing whether specific data exists.
  • Treat an 's authority and the consumer's identity as separate checks where both apply.
Question 2

What records explain a verification outcome?

Keep enough evidence to reproduce why a request passed, failed, or was handled at a particular assurance level without retaining unnecessary identity documents.

  • Request type, account status, requested data or action, sensitivity, and risk of harm.
  • Verification method, matching data points, source reliability, result, retries, and authorized-agent checks.
  • Additional information requested, why it was necessary, how it was protected, and when it was deleted.
  • Consumer notices, completion or denial reason, exception basis, owner, and review date.
Question 3

Which identity checks collect too much or prove too little?

Verification should reduce impersonation risk without turning the request process into a new source of sensitive personal information.

  • Applying the same identity check to every right and every data set.
  • Requiring identity verification for opt-out or limit requests.
  • Requesting a government identifier when less sensitive existing data can provide the required assurance.
  • Using new verification information for marketing, profiling, or any unrelated purpose.
  • Treating proof of an 's authority as proof of the consumer's identity.
Question 4

Questions and answers

Which CCPA requests require identity verification?

Requests to delete, correct, and know require a reasonable verification method. Requests to opt out of sale/sharing and requests to limit do not require identity verification, though the business may ask for information that is reasonably necessary to complete the request.

What methods should a business offer for delete, correct, and know requests?

A business that does not operate exclusively online and have a direct relationship with the consumer must provide two or more designated methods, including at least one toll-free telephone number. If the business operates exclusively online and has a direct relationship with the consumer, it only needs to provide an email address for these requests.

What can a business ask for when verifying a consumer?

The business should generally avoid asking for extra information. If it cannot verify the consumer from information already maintained, it may request additional information, but only for verification, security, or fraud-prevention purposes, and it should delete any new information as soon as practical after the request is processed, subject to record-keeping rules.

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Primary sources

References and citations

CPPA CCPA Regulations effective January 1, 2026
cppa.ca.gov4 citations
Referenced sections
  • Current binding rules for request methods, verification, authorized agents, security, and recordkeeping.
  • Sections 7060-7063 set the verification rules for accounts, non-accountholders, deletion, and authorized agents.
  • Sets verification, response, security, and consumer-request recordkeeping requirements.
Show 1 more
  • Distinguishes request types, prohibits verification for opt-out and limit requests, and limits additional verification data.
CPPA Enforcement Advisory No. 2024-01
cppa.ca.gov2 citations
Referenced sections
  • Agency guidance on proportionate, data-minimizing verification.
  • Agency guidance on applying data minimization when selecting and operating verification methods.

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