Verification Requirement

Definition

The legal obligation to confirm a requestor's identity before fulfilling privacy rights requests, protecting both the requestor's data and others' information from improper disclosure or deletion. Under GDPR Article 12, if controllers have reasonable doubts about requestor identity, they can request additional information necessary to confirm identity. Under CCPA regulations, businesses must verify requests to reasonable degrees based on request type and data sensitivity: access requests require matching at least two data points, deletion requests require at least three data points plus a signed declaration, and requests for sensitive information require heightened verification. Verification requirements balance competing interests—strong verification protects against fraudulent requests, but excessive requirements can effectively deny legitimate rights. Organizations must avoid: requesting verification information that itself violates privacy (like asking for sensitive data to verify an access request), using verification to discourage requests, or applying verification inconsistently. Verification should be proportionate to risks, clearly communicated to requestors, and documented for accountability purposes.

Applicable Laws & Regulations

  1. 1GDPR Article 12
  2. 2CCPA Regulations Section 999.323
  3. 3CPRA

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