Risk assessment before using ADMT or other high-risk processing
Applies from January 1, 2026
- When it relates
- Applies to CCPA-covered businesses (revenue threshold, 100,000 residents or 50% of revenue from selling data) that use ADMT for significant decisions, infer traits of employees, applicants or students through systematic observation, process sensitive data, or train ADMT or facial recognition. Training models on your own data is not enough by itself. For processing that began before 2026 the deadline is December 31, 2027.
- What the rule provides
- Conduct and document the assessment before starting the processing.
- Describe the specific purpose, data, concrete benefits, negative impacts and safeguards; involve the staff who take part.
- Have it approved by a person with authority over the processing.
- Review it at least every three years and update it within 45 days of a material change.
- Keep it while the processing continues or for five years after completion, whichever is later.
- For processing that already existed before January 1, 2026, the deadline is December 31, 2027.
- Typical evidence
- Signed, versioned risk assessment
- List of contributors and approver
- Related base documents
- Supporting documents
- Verification
- Verified in the official source on November 2, 2026Checked against the approved text published by CalPrivacy (§§ 7150 and 7155).