Opt-out requests processed within 15 business days
Why it matters
CCPA § 1798.120(c) and § 1798.135(b) require opt-out requests to be processed within 15 business days of receipt. For real-time client-side opt-outs — a cookie is set and pixels stop firing immediately — this deadline is automatically satisfied. The gap is backend-processing opt-outs: requests that require staff to remove the consumer from a CRM, advertising platform audience, or data broker list. Without a tracking system and documented SLA, there is no way to prove compliance, and regulators treat the absence of tracking as evidence of non-compliance. An opt-out form that routes to an unmonitored inbox with no SLA is a CCPA violation waiting for an enforcement trigger.
Severity rationale
Medium because the 15-business-day processing requirement under CCPA § 1798.120(c) is specific and auditable — a manual fulfillment queue with no SLA tracking is a documented non-compliance gap.
Remediation
For real-time cookie-based opt-outs, document that the 15-day deadline is satisfied automatically. For any backend processing (removing from CRM lists, third-party advertising audiences), persist an opt-out record with a timestamp and send the consumer a confirmation email.
// app/api/privacy/opt-out/route.ts — log, confirm, and schedule third-party removal
export async function POST(req: Request) {
const { email } = await req.json()
await db.privacyPreference.upsert({
where: { email },
create: { email, optedOutAt: new Date(), type: 'sale_sharing' },
update: { optedOutAt: new Date() },
})
await sendEmail({
to: email,
subject: 'Your opt-out has been processed',
body: 'Effective immediately. Third-party advertising lists updated within 15 business days.',
})
await notifyThirdPartiesOfOptOut(email)
return Response.json({ ok: true, processedAt: new Date().toISOString() })
}
Track third-party list removals in PRIVACY_OPERATIONS.md so you can demonstrate the 15-business-day SLA was met if a regulator asks.
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 · §1798.120(c) — Opt-out requests must be honored within 15 business days
- ccpa · §1798.135(b) — Third-party notification of opt-out — must be directed within 90 days
- nist:rev5 · PT-6 — Privacy reporting — response timeline for consumer requests
Taxons
History
- 2026-04-18·v1.0.0·Initial import from ccpa-readiness·automated