From Policy to Proof: Managing Operational Privacy Risk Under CPPA
Quarterly Risk Report – Q1 2026
This special Q1 2026 issue focuses on how privacy risk is shifting from written commitments to technical reality. As CPPA risk assessment requirements take effect, the report examines what regulators, courts, and plaintiffs are now looking for, and what organizations must be able to demonstrate in practice across their web properties.
In this issue, we uncover:
CPPA risk assessment requirements in practice
A breakdown of what the finalized rules require, where organizations are struggling, and why manual approaches no longer scale.
Real-world tracking behavior across enterprise websites
Aggregated findings from continuous scanning, including consent failures, pre-consent tracking, session replay usage, and third-party pixel exposure.
Consent enforcement and Global Privacy Control gaps
How consent tools behave technically, where opt-out signals fail, and why surface-level compliance is insufficient.
Litigation and enforcement risk tied to web tracking
Analysis of recent CIPA decisions and their implications for common tracking technologies such as pixels, SDKs, and scripts.
Building defensible, regulator-ready evidence
What a repeatable, auditable risk assessment program looks like, and how organizations are translating technical findings into durable documentation.
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