Privacy policy discloses categories of PI collected, purposes, and third parties
Why it matters
CCPA § 1798.130(a)(5) requires the privacy policy to disclose, for the 12-month period before the policy's effective date, the specific CCPA-defined categories of PI collected (identifiers, internet activity, geolocation, commercial information, inferences, sensitive PI, and others enumerated in Civil Code § 1798.140), the business purpose for each, the categories of third parties who receive the PI, and which categories are sold or shared for cross-context behavioral advertising. A vague policy that says "we may share data with partners" satisfies none of these requirements. If your policy is stale — no update in 12 months — it is non-compliant regardless of content. Regulators read privacy policies before filing enforcement actions; a CCPA-deficient policy is often exhibit A.
Severity rationale
Critical because a non-compliant or absent privacy policy violates CCPA § 1798.130(a)(5) on its face — it is the foundational document the law requires, and its absence or vagueness leaves every consumer request without a lawful basis for denial or fulfillment.
Remediation
Restructure your privacy policy using CCPA-defined category names from Civil Code § 1798.140 — not generic terms like "personal information" — and add distinct sections for PI sold/shared, consumer rights, and third-party disclosures.
## Categories of Personal Information We Collect
| CCPA Category | Examples We Collect | Business Purpose |
|-----------------------------|-------------------------|--------------------------|
| Identifiers | Name, email, IP address | Account creation, service|
| Internet/network activity | Pages visited, clicks | Analytics, improvement |
| Commercial information | Purchase history | Order fulfillment |
| Inferences | Inferred preferences | Personalization |
## Sale or Sharing of Personal Information
We share cookie IDs with Google and Meta for cross-context behavioral
advertising ("sharing" under CPRA § 1798.140(ah)).
## Your California Privacy Rights
[Know, Delete, Correct, Opt-Out, Limit SPI Use, Non-Discrimination]
Set a calendar reminder to update the policy within 12 months; CCPA requires it to be current. Add the effective date prominently at the top.
DetectionPro
The detection method for this pattern is part of AuditBuffet Pro.
The full method (what to look for, pass and fail conditions, and how results get reported) ships inside the CCPA/CPRA Readiness Audit. The pattern definition, severity rationale, and remediation remain openly licensed under CC-BY-4.0.
External references
- ccpa · §1798.100(b) — Privacy policy — categories of PI collected, purposes, and third-party recipients
- ccpa · §1798.115 — Required policy disclosures — categories sold or disclosed to third parties
- ccpa · §1798.130(a)(5) — Privacy policy — annual update and content requirements
- gdpr · Art. 13 — Information to be provided at collection
- nist:rev5 · PT-5 — Privacy notice
Taxons
History
- 2026-04-18·v1.0.0·Initial import from ccpa-readiness·automated