Change record
CA-C-001590
Substack Privacy Policy
Entity
Date detected
May 5, 2026
Effective date
May 5, 2026
Severity
Direction
Neutral
Taxonomy
Data collection expansion
Changes
+9 sentences added · 5 sentences modified

Impact Summary

Medium Neutral for users
Affected users
All users

Substack updated its privacy policy on May 5, 2026 to disclose that it shares account identifiers with child safety organizations to detect child sexual abuse material, added a one-month deadline for responding to privacy rights requests, and clarified that direct message recipients may retain messages even after deletion. The policy also now specifies that only material changes to the privacy policy will trigger user notification.

2 new obligations 1 obligation expanded

Consumers: You are now told that Substack shares your email and username with industry groups working to prevent child abuse online.

Consumers: When you ask Substack for your data or to exercise a privacy right, you now have a guaranteed timeline for their response instead of an indefinite wait.

Consumers: Substack is now clearer that even if you delete a message or your account, the person you sent it to can keep it forever.

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What this means for you

Substack now discloses that it shares account identifiers, such as email addresses and usernames, with trusted industry child safety organizations to detect and prevent online child sexual exploitation and abuse. The policy also establishes that Substack will respond to privacy rights requests within one month, or up to three months for complex requests, providing more certainty about response timelines. Additionally, the policy clarifies that direct message recipients may retain messages even if you request deletion or delete your account, which is now explicitly stated rather than implied.

Historical Context

ConductAtlas has recorded 2 material changes to this document (since April 2026).

Key Clauses Affected

Industry Child Safety Programs disclosure

Substack now explicitly states it shares account identifiers with child safety organizations to detect and prevent online child sexual exploitation and abuse.

Data subject rights response timeline

Substack commits to respond to privacy rights requests within one month, or up to three months for complex requests, with notification of extension.

Direct message retention clarification

Policy now clarifies that platform may restrict message access but recipients may retain messages indefinitely, regardless of user deletion or account closure.

Full clause-by-clause analysis available with Insight.

This change record describes what was added, removed, or modified in the document. Analysis reflects what the updated agreement states or permits. It does not constitute a legal determination about enforceability. Applicability may vary by jurisdiction. Methodology

Evidence Verification

✓ Verified
Previous Version
30dacb2f5c2daea0eee194830d934496ec1685219992cb84fb4d4dad988dba70
April 19, 2026 06:13 UTC
✓ Verified
Current Version
b7899fd21f6d5aa04ee2589121d23b47e86d4896e1fa797d920e873e2db1d5b5
May 5, 2026 05:44 UTC
✓ Verified
Change Detected
May 5, 2026 05:44 UTC
Analysis Methodology
✓ Verified
Source Document
https://substack.com/privacy
Citation Record
Entity: Substack
Document: Substack Privacy Policy
Record ID: CA-C-001590
Captured: 2026-05-05 05:44:17 UTC
URL: https://conductatlas.com/change/2026-05-05-substack-substack-privacy-policy-1590/
Accessed: Aug. 12, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
For legal and compliance teams

Institutional Analysis

Assessment

This change introduces a new disclosure about data sharing for child safety purposes and establishes formal response timelines for data subject rights requests. The child safety sharing disclosure engages GDPR Article 6 (lawful basis), CCPA …

🔒 Full institutional analysis

Regulatory exposure, obligation change, escalation trigger, board-ready language, and recommended action for legal and compliance teams.

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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-001590.

Full Changes

View complete diff →

Document Context

Version history → Policy drift analysis → Document page →
Document
Substack Privacy Policy
Entity
Substack
Captured
May 5, 2026
Source URL
https://substack.com/privacy
Other changes to Substack Privacy Policy
Previous change Apr 19, 2026
Substack's updated privacy policy removes language describing a one-month response timeline for certain privacy rights requests and eliminates explicit disclosure …
Medium Negative
Next change May 15, 2026
Substack updated its privacy policy on May 15, 2026 to disclose that it shares account identifiers with child safety industry …
Low Neutral
View full version history →
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