Artifact GuideUSDSAR and Correction Workflow

US CPRA DSAR and Correction Workflow

Route California requests to know, delete, and correct through one case record while preserving each right's verification standard, search scope, exceptions, system action, vendor action, and response.

The final CCPA regulations set a 10-business-day acknowledgement and a 45-calendar-day response clock that starts on receipt, not after verification.

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

DSAR means data subject access request, a common privacy-operations label. California law instead distinguishes requests to know, delete, and correct. A asks a CCPA-covered business to fix inaccurate personal information using commercially reasonable efforts. Route it with requests to know and delete through one case record, but keep the rights and outcomes separate. Confirm receipt within 10 business days and respond within 45 calendar days from receipt, including verification time. When necessary, one explained extension may increase the total response period to 90 calendar days.

Section 1

Route requests to know, delete, and correct

Confirm that the legal entity is a CCPA business and classify the request before searching systems. A business operating only online with a direct relationship to the consumer may provide an email request method. Other businesses must provide at least two methods, including a toll-free number and, when they maintain a website, a website method. A misdirected or technically deficient request must be treated as properly submitted or the consumer must receive instructions to fix it.

Match the verification strength to the right, data sensitivity, and harm from unauthorized action. For a non-accountholder, a categories request may use two reliable matching data points; a specific-pieces request may use three reliable matches plus a signed declaration. Deletion and correction require a reasonable or reasonably high degree of certainty based on risk. Try to verify a correction request with information other than the contested field.

A request to know covers the preceding 12 months by default. The consumer may ask for information collected on or after January 1, 2022 beyond that period unless production is impossible or would involve disproportionate effort. Do not disclose Social Security, government identification, financial or medical account, password, security-answer, or unique biometric values; describe the type with enough particularity instead.

For deletion, erase, deidentify, or aggregate covered information in active systems; notify service providers and contractors; and notify third parties that received a sale or sharing unless that is impossible or disproportionate. Archived or backup data may wait until restoration or next access. Delete non-exempt data, restrict any retained exempt data to the exception's purpose, and give a detailed partial or full denial.

For correction, decide whether the contested information is more likely than not accurate from the totality of the circumstances, including its nature, source, supporting records, consumer documentation, purpose, and consumer impact. Correct active systems and instruct service providers and contractors. Deletion may substitute only when it does not harm the consumer or the consumer consents.

  • Capture receipt, right asserted, request channel, business and consumer scope, account and authorized-agent context, acknowledgement date, 45-day deadline, extension notice and reason, and 90-day maximum deadline.
  • Match identity information already held before requesting more, collect only what verification needs, and apply stronger verification where unauthorized action would create greater harm.
  • Search named active, archived, and backup systems and every service provider or contractor; for access, include contracted personal information; preserve each result and the exact exception, impossibility, or disproportionate-effort facts.
  • Send correction or deletion instructions to applicable service providers and contractors, and send deletion notices to sale-or-sharing recipients unless the documented exception applies; record completion, delay, or refusal.
  • Deliver access data with reasonable security, state what was granted or denied, provide the required detailed explanation, and keep the request record for at least 24 months under section 7101.
Section 2

Fields to record for each consumer request

The privacy-operations owner should maintain the case record. Separate intake, verification, search, legal review, system action, recipient action, response, and closure so a reviewer can see where a request stalled and reproduce any denial.

  • Request ID, receipt and acknowledgement timestamps, asserted right, scope decision, authorized-agent evidence, and response clock.
  • Verification level, reliable matches, declaration when used, risk factors, data requested only for verification, result, and fraud or security escalation.
  • System, backup, service-provider, contractor, and third-party search or notice log; data located; access period; source and accuracy evidence; action; and exception provision.
  • Consumer response, prohibited-value handling, secure delivery method, extension or detailed denial explanation, owner, reviewer, downstream confirmations, closure date, minimum 24-month retention endpoint, and approved deletion date.
Section 3

Review deadlines and persistent corrections

Review missed deadlines, verification failures, repeated correction disputes, incomplete downstream responses, and inconsistent exceptions. Re-test after identity, account, data-store, retention, or vendor changes, and sample closed cases to confirm that the response matches recorded system actions.

  • Measure acknowledgement and response time from receipt even when verification remains open; record which cases used the one extension and why it was necessary.
  • Test whether corrected information stays corrected when systems synchronize or a data broker later supplies the old value.
  • For a repeated correction request within six months, treat it as new when the consumer supplies new or additional accuracy documentation; document any fraud or abuse conclusion.
  • Sample deletion exceptions, backup delays, third-party notices, access lookback decisions, and secure delivery against the final consumer response.
Primary sources

References and citations

cppa.ca.gov
Referenced sections
  • CPPA regulations source for operational CCPA request handling, notices, verification, and workflow controls.
"On March 29, 2023, the Office of Administrative Law approved the California Privacy Protection Agency’s regulations and filed them with the Secretary of State."
cppa.ca.gov
Referenced sections
  • CPPA FAQ source confirming CPRA amendments added consumer privacy rights and business obligations relevant to DSAR intake.
"The CPRA amended the CCPA by adding additional consumer privacy rights and obligations for businesses"
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