What should teams do about retention under the California CPRA?
A covered business must disclose at collection how long it intends to retain each category of personal information or, when a fixed period is not possible, the criteria it uses to determine that period. The business cannot retain a category longer than reasonably necessary for the disclosed purpose for which it was collected.
Build retention by data category and purpose. For each record set, identify the collection notice, primary and compatible purposes, minimum period needed, legal or operational dependency, deletion or deidentification event, system owner, and exception handling. An objective criterion should identify the event and rule used to calculate a deletion date. A bare statement such as "we keep data as long as necessary" does not explain the criteria or show that systems can execute them.
Section 7002 also limits collection, use, retention, and sharing to what is for a disclosed compatible purpose or a purpose covered by valid consent. A new incompatible purpose requires fresh notice and consent before processing. Separate routine retention from records preserved for a legal obligation, dispute, security investigation, or applicable deletion exception, and restrict retained exception data to that purpose.
- State a period or objective criteria for every disclosed personal-information category.
- Configure deletion or deidentification in active systems, vendors, analytics stores, and restored backups, with an owner and test date.
- Record the legal basis and access restriction for each hold or exception; do not convert one exception into indefinite general retention.
Binding CCPA/CPRA data-minimization rule limiting retention to what is reasonably necessary and proportionate.
CPPA regulations page for current CCPA regulations implementing CPRA amendments and privacy-practice disclosures.
CPPA FAQ explains the practical rule that collection, use, and retention must be limited to expected, compatible, or consented purposes.
Sections 7002 and 7012 set the purpose, necessity, proportionality, consent, new-notice, and category-level retention-disclosure rules.