The California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), introduced a specific right allowing consumers to limit the use and disclosure of their sensitive personal information. This right operates differently from access, deletion, and opt‑out rights and focuses on restricting how certain categories of data may be used after collection. This article explains what qualifies as sensitive personal information, how the limitation right works, how consumers exercise it, and how businesses must translate limitation requests into operational controls and documentation.
Handling Requests to Limit the Use of Sensitive Personal Information Under the CCPA
The CPRA expanded the CCPA’s consumer rights framework by creating additional protections for sensitive personal information. While often mentioned alongside opt‑out rights, the right to limit the use of sensitive personal information serves a different purpose and introduces different operational challenges for businesses.
Rather than stopping the sale or sharing of data, this right focuses on restricting how certain types of personal information may be used internally or disclosed, even when the underlying collection remains lawful. For businesses, this means distinguishing between data that can continue to be used for limited purposes and data uses that must be curtailed once a limitation request is applied.
In this article we look at how requests to limit the use of sensitive personal information work under the CCPA and CPRA, how this right differs from other consumer rights, and how businesses can approach limitation handling as part of a broader consumer rights program.
For a more comprehensive overview of all CCPA and CPRA consumer rights and how they fit together, see our associated articles on consumer rights under the CCPA and CPRA.
What is sensitive personal information under the CCPA?
Sensitive personal information is a defined subset of personal information that receives heightened protections under the CPRA amendments to the CCPA. While all personal information is subject to consumer rights, sensitive personal information is treated differently because of the potential impact on individuals if it is misused.
Examples of sensitive personal information include, among others:
- Government identifiers such as Social Security numbers and passport numbers
- Account log-in credentials and financial account information
- Precise geolocation data
- Racial or ethnic origin, religious beliefs, and similar attributes
- Genetic data and biometric information used for identification
- Information concerning a consumer’s sex life or sexual orientation
- The contents of private communications
These categories build on the broader definition of personal information under the CCPA, but they introduce additional obligations when consumers exercise their right to limit use.
What does it mean to limit the use of sensitive personal information?
The right to limit the use of sensitive personal information allows consumers to restrict how businesses use or disclose that data after it has been collected. This right does not automatically require deletion, nor does it necessarily prohibit collection.
In practice, limiting use means that sensitive personal information may only be used to provide the requested goods or services that an average consumer would reasonably expect, or for other limited business purposes expressly permitted under the CCPA and CPPA regulations.
This distinction is important. Limiting use is not the same as opting out of sale or sharing. While opt‑out rights focus on stopping certain disclosures to third parties, limitation rights focus on narrowing the range of permitted uses of the data itself.
For comparison, see how opt‑out rights operate in our article on handling opt‑out requests under the CCPA.
How consumers exercise the right to limit the use of their sensitive personal information
Like opt‑out rights, limitation rights are typically exercised through website interfaces rather than traditional data subject request workflows. Consumers are not expected to submit a detailed request or justify their choice.
Limitation links and interfaces
Businesses that use sensitive personal information beyond permitted purposes must provide a clear mechanism for consumers to exercise this right, commonly labeled “Limit the Use of My Sensitive Personal Information.”
In some cases, this mechanism may be implemented through a recognized preference signal or equivalent interface permitted under the CPPA regulations. This mechanism allows consumers to express their preference directly and without unnecessary steps. It should be presented in a manner consistent with how other consumer rights are made available across the website.
Relationship to other consumer rights
Limitation requests differ from access, deletion, and correction requests. They do not generally require the disclosure or modification of personal information and therefore do not follow the same verification or response‑timeline rules.
For background on those differences, see our associated guides on access, deletion, or correction requests under the CCPA.
Do limitation requests require identity verification?
In most cases, requests to limit the use of sensitive personal information do not require identity verification, particularly when the limitation can be applied without accessing or modifying sensitive account-level data. Because the request does not involve releasing data or changing core account information, the associated risk profile is lower than for access or deletion requests.
Verification practices should still be reasonable and proportionate. More detail on verification expectations is available in our guide on verifying identity under the CCPA.
How quickly must limitation requests be applied?
The CCPA does not assign a 45‑day response period to limitation requests. Instead, businesses are expected to apply limitations as soon as practicable after the consumer exercises the right.
This expectation that limitations be applied as soon as practicable mirrors opt-out handling rather than traditional data subject request timelines.
For a comparison with request‑based timelines, see the CCPA 45‑day response timeline.
What must change after a limitation request is exercised
Applying a limitation request requires more than flagging a preference. Businesses must evaluate how sensitive personal information is used across systems and restrict uses that fall outside permitted purposes.
Typical operational impacts
Area | Common adjustment |
|---|---|
Analytics and profiling | Restricting employee or system access to sensitive data |
Third‑party disclosures | Limiting use of sensitive data in analytics or inference activities beyond permitted business purposes |
Retention practices | Narrowing disclosures to permitted service providers |
These changes require coordination between legal, technical, and operational teams.
Practical examples
Example 1: limiting internal use
A consumer exercises the right to limit the use of their precise geolocation data. The business continues to use the data to provide location‑based services requested by the consumer but restricts its use for internal analytics unrelated to service delivery.
Example 2: limiting third‑party disclosure
A limitation request applies to financial account information collected during a transaction. The business continues to process the transaction but restricts disclosures of that data to only those service providers necessary to complete payment processing.
Recordkeeping and documentation
Although limitation requests are not processed through a traditional data subject request workflow, businesses are expected to maintain reasonable documentation demonstrating how limitation choices are handled.
This may include:
- When and how limitation choices were received
- Which categories of sensitive personal information were affected
- What uses were restricted as a result
- How consistency was maintained across systems
This documentation supports internal governance and regulatory inquiries and aligns with broader CCPA expectations around accountability and data minimization.
How limitation rights fit into broader CCPA obligations
The right to limit the use of sensitive personal information complements other consumer rights rather than replacing them. It interacts with:
- Data classification and mapping
- Consent and preference management
- Access, deletion, and correction workflows
- Internal policy enforcement
For a consolidated view of these obligations, see our CCPA compliance guide for businesses.
How Clym supports limitation handling
Managing limitation requests requires clear consumer interfaces, internal controls, and consistent recordkeeping. Clym provides tools that support these activities as part of a structured privacy program that helps businesses facilitate compliance with the CCPA.
With Clym, businesses can:
- Provide consumers with a centralized interface to express limitation preferences through the Clym widget and dedicated links, allowing limitation choices to be captured and managed consistently
- Configure consent and preference logic to reflect limitation choices across relevant systems using Clym’s Consent Management solution
- Organize limitation activity alongside other consumer rights actions using Data Subject Request Management, maintaining visibility across rights types
- Maintain records of limitation handling and internal actions in the Clym Control Center, supporting audits and internal reviews
By integrating limitation handling with broader privacy workflows, Clym supports a practical approach to managing sensitive personal information under the CCPA.
Key takeaway
The right to limit the use of sensitive personal information adds an additional layer of responsibility for businesses handling California residents’ data. Understanding what qualifies as sensitive personal information, how limitation requests are exercised, and how those requests translate into operational restrictions is central to managing this right effectively.
Frequently asked questions
Sensitive personal information is a defined subset of personal information that includes data such as government identifiers, financial account information, precise geolocation, genetic and biometric data used for identification, information concerning a consumer’s sex life or sexual orientation, and the contents of private communications.
No. Limiting the use of sensitive personal information restricts how sensitive personal information may be used or disclosed after collection. Opt-out rights focus on stopping certain disclosures of personal information to third parties for sale or sharing purposes.
Not necessarily. Limitation requests restrict certain uses of sensitive personal information but do not automatically require deletion or prohibit collection when the data is needed for permitted purposes under the CCPA and CPPA regulations.
Limitation requests should be applied as soon as practicable after they are exercised. The 45-day response period that applies to access, deletion, and correction requests does not apply to limitation preferences.
In most cases, no. Because limitation requests do not typically involve disclosing personal information, verification expectations are generally lower than for access or deletion requests. Verification may be appropriate if applying the limitation requires access to sensitive account-level data.
Yes. When a consumer exercises the right to limit use, the restriction applies to the ongoing use and disclosure of previously collected sensitive personal information, not only to data collected after the preference is expressed.
The right to limit applies primarily to businesses that determine how sensitive personal information is used. Service providers and contractors must follow limitation instructions received from the business and may only use sensitive personal information for purposes permitted by their contracts and the CCPA.
Yes. Consumers may change or withdraw limitation preferences at any time using the same or an equivalent mechanism through which the preference was originally expressed. Updated preferences should be applied consistently across relevant systems.
If sensitive personal information has been disclosed to service providers, contractors, or third parties, businesses are expected to take reasonable steps to communicate applicable limitation instructions so that downstream use reflects the consumer’s preference.
Alex is a Content Developer at Clym, where he researches and writes about everything related to data privacy and web accessibility compliance for businesses, helping them stay informed on their compliance needs and spreading awareness about making the web safer and more inclusive. When he’s not writing about compliance, Alex has his nose in a book or is hiking in the great outdoors.
Find out more about Alex