Artifact GuideUSPersonal and Sensitive Information

US CCPA Personal and Sensitive Information

Classify and by the statutory definitions, then map collection, use, disclosure, retention, sale, sharing, limitation rights, and security controls.

For data, privacy, security, product, and vendor teams classifying fields, uses, inferences, and recipient flows.

Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
Overview

Classify information by what it can reasonably identify, describe, or link to a consumer or household, not by its database label. is a defined subset of with additional notice and limit-use consequences. Use this guide to separate covered data from statutory exclusions and to connect each category to the controls it changes.

Section 1

Apply linkability, sensitive-category, and exclusion tests

Start by identifying what the CCPA treats as and . Personal information is information that identifies, relates to, or could reasonably be linked to a particular consumer or household, and the CCPA gives examples such as a name, email address, records of products purchased, internet browsing history, geolocation data, fingerprints, and inferences about preferences and characteristics.

is a narrower set that includes government identifiers; account credentials or financial-account access information; ; racial or ethnic origin, citizenship or immigration status, religious or philosophical beliefs, union membership, and mail, email, or text contents when the business is not the intended recipient; genetic and neural data; biometric information processed to uniquely identify a consumer; and collected and analyzed about health, sex life, or sexual orientation. Under the regulations effective January 1, 2026, it also covers personal information of consumers the business has actual knowledge are under 16.

Publicly available, lawfully obtained truthful information that is a matter of public concern, and deidentified or aggregate consumer information are excluded from under specific statutory conditions. A record does not become excluded merely because it can be found online or because direct identifiers were removed.

  • Identify the actual data element, how it is obtained, the consumer or household link, and whether it is used to infer another characteristic.
  • Check the sensitive-personal-information definition element by element; sensitivity in ordinary speech is not the legal test.
  • Test any public-information or deidentification exclusion against all statutory conditions and document the source and safeguards.
  • Map the final category to notice, access, deletion, correction, retention, security, sale, sharing, and limit-use controls.
Section 2

Assign classification owners and connect affected controls

Data owners should describe the field and use; privacy or legal should approve classification and exclusions; engineering and security should map systems and safeguards; and product, marketing, and procurement should document recipients and sale or sharing.

Keep a data dictionary, sample values or schemas that avoid unnecessary live , source, purpose, retention, recipients, inference logic, classification rationale, and links to the notices and rights workflows affected.

  • Record whether is used only for purposes allowed by the regulations or whether the right to limit must be offered.
  • Treat inferences as their own data product when the business creates a profile about preferences, characteristics, behavior, attitudes, abilities, or similar traits.
  • Reclassify when a field is combined with new identifiers, used for identification, or analyzed to reveal a protected characteristic.
  • Review category maps when collection, models, vendors, retention, or disclosure purposes change.
Section 3

Resolve biometric, location, communication, and inference boundaries

Biometric information is when processed for the purpose of uniquely identifying a consumer. A photograph, voice recording, or keystroke pattern still may be even when that sensitive-category test is not met.

means a location derived from technology that identifies a consumer within a geographic area no larger than a circle with a radius of 1,850 feet, subject to the statutory exception for certain content of communications. General city or region information may remain without meeting that precise-geolocation test. Message content is sensitive only when the business is not the intended recipient, while metadata may fit other personal-information categories.

  • Do not classify encrypted or hashed identifiers as deidentified without the required technical and organizational measures against reidentification.
  • Do not omit household information merely because no named individual is present.
  • Do not treat an inference as outside scope because its underlying source data was public.
  • Do not assume a sectoral exemption covers the entire entity; many CCPA exemptions attach to specified information or activities.
Section 4

Classify each field and use before updating public categories

Classify at field and use-case level, then group fields into consumer-facing CCPA categories for notices and rights responses. The internal record should remain specific enough to reproduce the classification and locate the data.

Apply a change trigger whenever a team adds an identifier, creates an inference, changes a biometric or location use, combines data sets, or changes a recipient or purpose.

  • Describe the data element, source, linkability, processing purpose, and any inferred characteristic.
  • Apply the personal-information definition, then the sensitive subset and each claimed exclusion.
  • Record systems, retention, recipients, sale or sharing, allowed sensitive uses, and affected rights.
  • Update notices and controls before introducing a new category or materially different use.
Primary sources

References and citations

cppa.ca.gov4 citations
Referenced sections
  • Current official text for the regulatory addition of known under-16 information to sensitive personal information and related category rules.
  • Section 7001 adds personal information of consumers the business actually knows are under 16 to sensitive personal information.
  • Sections 7002 and 7012 support data-minimization evidence by tying category handling to reasonably necessary and proportionate collection, use, retention, and sharing.
Show 1 more
  • The consolidated official text supports the 1,850-foot precise-geolocation boundary and the current sensitive-personal-information definition.
"reasonably necessary and proportionate to achieve"
leginfo.legislature.ca.gov4 citations
Referenced sections
  • Supports CCPA category disclosures by requiring notice of collected personal-information and sensitive-personal-information categories, purposes, sale or sharing, and retention.
  • Supports the notice-at-collection rule requiring businesses to disclose personal-information and sensitive-personal-information categories, purposes, sale or sharing, and retention.
  • Supports edge-case review when new category collection, incompatible secondary use, sale or sharing, or retention changes require updated notice.
Show 1 more
  • Operational support for mapping each personal-information category to purpose, retention, and compatibility controls.
"categories of personal information to be collected"
More quoted passages
"the categories of personal information to be collected"
"shall not collect additional categories"
"reasonably necessary and proportionate"
leginfo.legislature.ca.gov4 citations
Referenced sections
  • Supports statutory category classification by defining personal information and sensitive personal information for CCPA scope decisions.
  • Provides the statutory definitions that determine whether data falls into CCPA personal-information or sensitive-personal-information categories.
  • Supports category boundary review because CCPA definitions decide whether records, identifiers, inferences, or sensitive data are in scope.
Show 1 more
  • Operational support for classifying records against the statutory personal-information and sensitive-personal-information definitions.
"identifies, relates to, describes, is reasonably capable of being associated with"
More quoted passages
"could reasonably be linked"
"sensitive personal information"
cppa.ca.gov3 citations
Referenced sections
  • Non-binding CPPA FAQ identifying the CCPA rights tied to personal-information and sensitive-personal-information categories.
  • Non-binding CPPA FAQ listing examples of sensitive personal information tied to the right to limit.
  • Non-binding CPPA FAQ connecting sensitive-information categories to consumer limit-use choices.
"Consumers have the right to limit"
More quoted passages
"precise geolocation"
"right to limit"
cppa.ca.gov2 citations
Referenced sections
  • Non-binding CPPA FAQ explaining personal information and sensitive personal information in consumer-facing terms.
  • Non-binding CPPA FAQ explaining the public-facing distinction between personal information, sensitive personal information, and the right to limit sensitive-information use.
"Personal information includes sensitive personal information"
leginfo.legislature.ca.gov
Referenced sections
  • Supports category evidence by requiring businesses to disclose purposes, sale or sharing status, and retention for each category.
"categories of sensitive personal information to be collected"
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