Artifact GuideUSCPRA Risk Assessment Template

US CPRA CPRA Risk Assessment Template

Use this working template before a CCPA-covered business starts any processing listed in section 7150, including sale or sharing, sensitive-data processing, covered profiling, and specified ADMT or AI uses.

It maps the final CPPA regulations effective January 1, 2026 to the report fields, approval, update, retention, and Agency-submission records a business must maintain.

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

A is the documented CPPA analysis that a CCPA-covered business must complete before starting any processing listed in section 7150. The listed activities include selling or sharing personal information, processing sensitive personal information, using ADMT for a significant decision, specified profiling, and training ADMT or identity, biological-identification, or profiling technology with personal information. Covered processing that began before January 1, 2026 and continues afterward must be assessed by December 31, 2027. Review each assessment at least once every three years and update it within 45 calendar days after a material change.

Section 1

How to complete the risk-assessment template

Use this template only after intake identifies a section 7150 trigger. Complete and approve it before new covered processing starts. One report may cover a comparable set of similar activities only when they present similar privacy risks. A report prepared for another law may be reused only if it contains every section 7152 item or is paired with the missing California information.

The report must state a specific purpose; the personal information and minimum data necessary; collection, use, disclosure, retention, consumer interaction, scale, notices, and recipients; benefits; negative privacy impacts and their causes; safeguards; the launch decision; contributors; and approval by someone authorized to help decide whether processing starts. For covered ADMT used for a significant decision, it must also explain the logic, assumptions or limits, output, and how the output affects the decision. The regulatory goal is to restrict or prohibit the processing when privacy risks outweigh the benefits.

The sensitive-personal-information trigger has a narrow employment exception. No assessment is required when employee or independent-contractor sensitive information is processed solely and specifically for compensation payments, employment authorization, benefits, legally required accommodation, or wage reporting. Other sensitive-information processing remains subject to section 7150.

  • Define one processing activity, its purpose, start date, products, systems, consumers, geography, data sources, recipients, retention, and responsible business.
  • List each personal-information category and explain why it is the minimum necessary for the stated purpose.
  • Describe operational elements, including collection method and sources, each retention period or criterion, consumer interaction, approximate consumer count, notices, recipients and purposes, sale or sharing, profiling, and ADMT or AI training.
  • Assess concrete benefits and negative impacts such as unauthorized access, unlawful discrimination, loss of consumer control, coercion, economic or physical harm, reputational harm, and psychological harm; identify causes and map each safeguard to the impact it reduces.
  • Include employees who supply facts about the processing. Record optional external input, contributors other than counsel giving legal advice, the authorized approver, launch decision, approval date, three-year review date, 45-day material-change deadline, and submission status.
Section 2

Fields to record for each assessment

The business's assessment owner should maintain this record with the product, privacy, security, data, and operational employees who know how the processing works. Each field supports the section 7152 report and the later summary submission. This page is Sorena's implementation aid, not a CPPA form, safe harbor, or prescribed wording.

  • Assessment ID, business, activity, section 7150 trigger, purpose, planned or original start date, products, systems, and consumers affected.
  • Personal-information categories, sensitive categories, sources, retention, recipients, minimum-necessary rationale, and data-flow evidence.
  • Operational elements, consumer count, notices, recipients and purposes, benefits by stakeholder, negative impacts and causes, affected groups, safeguards, and remaining risk.
  • Employee and optional external input, contributors, authorized approver, balance conclusion, launch decision, next three-year review, material-change date and 45-day update deadline, and Agency-submission record.
Section 3

Review, changes, retention, and submission

Review each assessment at least once every three years, not annually. Update it as soon as feasible and no later than 45 calendar days after a material change creates a new negative impact, increases the magnitude or likelihood of an identified impact, or weakens a safeguard. Keep original and updated versions for as long as the processing continues or for five years after completion of the assessment, whichever is later.

  • For assessments conducted in 2026 or 2027, submit the section 7157 summary information and executive attestation by April 1, 2028; for later years, submit by April 1 following the year in which an assessment was conducted or updated.
  • Submit the count of assessments by trigger, information-category indicators, reporting period, contact, and attestation. Do not send the full reports routinely, but keep them ready because the Agency or Attorney General may demand them with 30 calendar days' notice.
  • Reopen the report after complaints, purpose or minimum-data changes, new recipients or model outputs, higher-risk populations, or weakened safeguards; record whether the 45-day material-change test was met.
  • Sample retained evidence against the report, approval, launch record, and submission receipt so each conclusion can be reproduced.
Primary sources

References and citations

csrc.nist.gov4 citations
Referenced sections
  • Voluntary, non-binding NIST assessment guidance; it does not define or satisfy the CPPA risk-assessment requirements.
  • Voluntary, non-binding NIST assessment guidance; it does not prescribe CPPA risk-assessment template fields.
  • Voluntary, non-binding NIST assessment guidance; it does not establish the CPPA review or submission rules.
"assessments of security and privacy controls"
More quoted passages
"methodology and set of procedures for conducting assessments"
"procedures are customizable and can be easily tailored"
"guidance on analyzing assessment results"
cppa.ca.gov3 citations
Referenced sections
  • Official CPPA rulemaking page confirming approval and effectiveness of the binding March 2023 CCPA regulations; the risk-assessment requirements come from the separately cited final 2026 text.
  • Official CPPA rulemaking page confirming approval and effectiveness of the binding March 2023 CCPA regulations; the 2026 risk-assessment fields come from the separately cited final 2026 text.
  • Official CPPA rulemaking page confirming approval and effectiveness of the binding March 2023 CCPA regulations; the 2026 review rules come from the separately cited final 2026 text.
"On March 29, 2023, the Office of Administrative Law approved the California Privacy Protection Agency’s regulations and filed"
cppa.ca.gov3 citations
Referenced sections
  • Supports the template's CPRA risk-assessment trigger, report fields, stakeholder inputs, and submission cadence.
  • Workflow support from CPPA's final risk-assessment regulations, including when a report is required and what it must document.
  • Review support from CPPA's risk-assessment submission and update requirements.
"Identify and document in a risk assessment report"
More quoted passages
"A business must conduct a risk assessment before initiating that processing"
"Submission of Risk Assessments to the Agency"
csrc.nist.gov3 citations
Referenced sections
  • Voluntary, non-binding NIST control guidance; it does not define or satisfy the CPPA risk-assessment requirements.
  • Voluntary, non-binding NIST control guidance; it does not prescribe CPPA risk-assessment template fields.
  • Voluntary, non-binding NIST control guidance; it does not establish the CPPA review or submission rules.
"This publication provides a catalog of security and privacy controls for information systems and organizations"
cppa.ca.gov
Referenced sections
  • Supports this page's CPRA Risk Assessment Template analysis under the US CPRA.
"The CPRA amended the CCPA by adding additional consumer privacy rights and obligations for businesses"
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