Deletion that has to reach the new copy.
Section 1798.105(c)(1) says that on a verifiable consumer request, a business deletes personal information it collected from the consumer and directs service providers, contractors, and third parties to delete it, unless doing so is impossible or involves disproportionate effort. Subsection (d) lists exceptions (contract performance, proportionate security, debugging, research, legal obligation, and others). A diff can show a new copy the delete path does not reach. It cannot decide whether an exception applies.
The shapes the same control failure takes.
Deletion breaks when a copy of personal information sits somewhere the delete path does not know about. The recurring shapes:
A new store is not on the delete path
A cache, search index, warehouse, or export starts holding personal information, and the existing delete-my-data job is not updated.
A hard delete becomes a flag
The row is marked deleted and the personal information remains indefinitely, which is not deletion unless a later step actually removes it.
Related rows are left behind
The primary profile is removed and events, notes, or files that still identify the person are not.
A processor is never told
The same personal information was sent to a vendor, and the deletion is not propagated, so a downstream copy remains.
There is no working consumer-delete path
A new product surface collects personal information and the only deletion story is a manual ticket.
A search index the delete job does not clear.
A people-search feature upserts name and email into an index on every profile save. The account-deletion job still only deletes the users row.
async function onUserUpdated(user: User) { await db.users.save(user)+ await searchIndex.upsert({ id: user.id, name: user.name, email: user.email })}This adds a copy of name and email that the deletion job does not clear. § 1798.105(c)(1) expects a verifiable deletion request to reach the personal information collected from the consumer, and to be passed downstream, unless a § 1798.105(d) exception applies. Wire the index into the delete path, or document why an exception covers this copy. The review cannot decide the exception for you.
What a privacy reviewer would verify
A privacy review checks whether a documented deletion request can reach every store that holds personal information collected from the consumer, and whether vendors are told. Exceptions in § 1798.105(d) are real. The useful finding on a pull request is a new copy with no path, not a verdict that a specific request must be granted.
A review, not a request desk.
A pull-request review can identify code and configuration that may conflict with an established deletion design. It cannot determine whether CCPA applies, whether a request is verifiable, or whether an exception applies. Select CCPA in org config if you want this duty reviewed. These pages are illustrative.