CA-C-000695 Top 5% Change
GitHub — GitHub Privacy Statement
Entity
Date detected
April 28, 2026
Effective date
April 27, 2026
Severity
High
Direction
Negative
Affected users
all users eu users uk users business accounts enterprise customers
Taxonomy
Ai training rights
Changes
+3 sentences added · −2 sentences removed · 8 sentences modified
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What Changed

GitHub updated its Privacy Statement on April 28, 2026, making several notable changes to how your data can be used. The policy now explicitly states that your data — including AI outputs — can be used to train and improve artificial intelligence and machine learning technologies, and this data can be shared with Microsoft and other affiliates for that purpose. Previously, the policy included specific protections describing when GitHub staff could access private repositories; that detailed list has been removed and replaced with a general reference to the Terms of Service.

Consumer Impact (what this means for users)

GitHub's updated policy now explicitly permits your personal data, including AI outputs, to be used for training and improving AI and machine learning models, and this data may be shared with Microsoft and other affiliates for that purpose. Previously, the policy contained a specific, enumerated list of circumstances under which GitHub staff could access your private repositories; that list has been removed, leaving protections less clearly defined and pointing users to the Terms of Service instead. You can review GitHub's privacy settings and, if applicable, submit a data subject request to limit certain processing of your personal data.

Obligation Changes (what shifted)

2
New obligations
2
Expanded
1
Protection removed
Consumers Added

Your data and AI-generated outputs can now be used to train GitHub's and Microsoft's AI systems.

Data controllers Expanded

GitHub can now share your data with Microsoft specifically for AI training, which is a broader use than before.

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Applicable regulations

EU AI Act
European Union
CCPA/CPRA
California, USA
CFAA
United States Federal
CAN-SPAM
United States Federal
DMCA
United States Federal
DSA
European Union
GDPR
European Union
UK GDPR
United Kingdom

Why It Matters (compliance & risk perspective)

This change means GitHub can now use your code, documents, and AI outputs to train AI models and share them with Microsoft for that purpose — a significant expansion of how your data is used. The removal of explicit private repository access protections also makes it harder to understand the limits on who at GitHub can see your private code.

📈 Historical Context

Across all monitored documents, GitHub has made 2 significant changes.

2 of GitHub's significant changes have been classified as negative for consumers.

Key Clauses Affected

AI/ML Training Data Use

GitHub now explicitly uses personal data, including AI outputs, to train and improve artificial intelligence and machine learning technologies.

Affiliate Data Sharing for AI Training

Personal data may now be shared with Microsoft and other affiliates specifically for AI/ML training and product development, with affiliates no longer required to follow GitHub's Privacy Statement.

Private Repository Access Protections

The explicit enumerated list of conditions permitting GitHub staff to access private repositories has been removed from the Privacy Statement and replaced with a reference to the Terms of Service.

Full clause-by-clause analysis available with Watcher.

Evidence Verification

✓ Verified
Previous Version
7afdab332a4ccd23b842e1a6cb1bd703216d892c4eb4a8b9784c01a28d6a288f
April 19, 2026 06:22 UTC
✓ Verified
Current Version
b36cbcc068012375c4a0d88eb7699d8a007a4c8b93ea435d81210244c50bf16d
April 28, 2026 06:21 UTC
✓ Verified
Change Detected
April 28, 2026 06:21 UTC
How to Cite
ConductAtlas Policy Archive
Entity: GitHub | Document: GitHub Privacy Statement | Record: CA-C-000695
Captured: 2026-04-28 06:21:11 UTC
URL: https://conductatlas.com/change/2026-04-28-github-github-privacy-statement-695/
Accessed: May 2, 2026

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Institutional Analysis (Compliance & legal intelligence)

Assessment

GitHub's April 28, 2026 update materially expands data use rights: personal data (now explicitly including AI outputs) may be used for AI/ML training and improvement, and shared with Microsoft and affiliates for that purpose. The prior explicit restriction on private repository access by GitHub personnel has been removed, replaced by a reference to the Terms of Service. This touches GDPR Art. 5(1)(b) (purpose limitation), Art. 13/14 (transparency), and CCPA/CPRA data use disclosures. Organizations using GitHub for software development — especially those handling regulated data — should reassess their vendor risk posture and DPAs immediately. Action is required.

Regulatory Exposure

1. GDPR Art. 5(1)(b) — Purpose limitation: expanding data use to AI/ML training may constitute incompatible secondary processing requiring a new legal basis or user consent.

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ConductAtlas provides verified policy intelligence sourced directly from platform documents. All analysis is intended to support, not replace, legal and compliance review. Record CA-C-000695.

Clause-Level Changes

New Provisions Added
De-identified and Aggregate Data Use
Medium

This new provision explicitly exempts de-identified and aggregate data from privacy protections, enabling unrestricted use and sharing for any purpose.

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Data Retention
Medium

This new provision establishes a general indefinite retention standard with multiple qualifying factors, replacing the previous vague reference to data retention.

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Provisions Removed
AI/ML Training Data Use
High

The removal of explicit AI/ML training data provisions eliminates disclosed restrictions on how user data is used for machine learning purposes, a significant omission given GitHub's Copilot services.

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California Resident Rights (CCPA/CPRA)
Medium

The removal of CCPA/CPRA-specific provisions eliminates explicit protections for California residents, though general rights provisions remain.

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Payment and Financial Data Collection
Low

The removal of explicit payment data provisions leaves unclear how financial information collected for billing is handled and protected.

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Provisions Modified
Law Enforcement and Government Disclosure
High

Previous version had no excerpt provided; current version now includes detailed disclosure conditions and explicit mention of law enforcement discretion.

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Microsoft and Affiliate Data Sharing
Medium

Previous version had no excerpt; current version now explicitly states GitHub is a Microsoft subsidiary and clarifies data sharing is governed by Microsoft agreements.

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Cookies and Advertising Tracking
Medium

Previous version had no excerpt; current version adds explicit disclosure of interest-based advertising and cross-site tracking partnerships.

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User Rights — Access, Deletion, and Portability
Medium

Previous version had no excerpt; current version now includes specific contact method and response timeline commitment.

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Children's Privacy — Minimum Age Restriction
Medium

Previous version had no excerpt; current version adds specific contact mechanism and deletion commitment for unauthorized child data collection.

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Cross-Border Data Transfers
High

Previous version had no excerpt; current version now includes explicit acknowledgment that U.S. privacy laws may be less comprehensive than user's home country.

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Cross-platform context

See how other platforms handle similar provisions across the ConductAtlas archive.

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Full Changes

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Document Context

Document
GitHub Privacy Statement
Entity
GitHub
Captured
April 28, 2026
Source URL
https://docs.github.com/en/site-policy/privacy-policies/github-general-privacy-statement
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