CA-C-001699
Substack — Substack Privacy Policy
Entity
Date detected
May 6, 2026
Effective date
May 6, 2026
Severity
Low
Direction
Positive
Affected users
all users
Taxonomy
Transparency removal
Changes
1 sentence modified
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Event Summary

Substack's privacy policy now discloses that the company shares account identifiers with child safety industry consortia to detect child sexual abuse material (CSAM). This is a new transparency disclosure added on May 6, 2026, informing users that their account information may be shared with industry organizations working to identify and report CSAM.

LOW

Consumer Impact

Substack has added a disclosure stating that account identifiers are shared with child safety industry consortia to detect child sexual abuse material. This transparency notice informs users of a data-sharing practice related to safety and legal compliance. The disclosure itself does not change the underlying data-sharing practice but makes it explicit in the privacy policy.

Governance Analysis

This disclosure makes explicit a data-sharing practice related to child safety and legal compliance. Transparency about how user data is used for safety purposes is important for user trust and regulatory compliance under laws like COPPA.

Key Clauses Affected

CSAM Detection Data Sharing Disclosure

Substack now explicitly discloses that account identifiers are shared with child safety industry consortia to detect and report CSAM.

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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
b7899fd21f6d5aa04ee2589121d23b47e86d4896e1fa797d920e873e2db1d5b5
May 5, 2026 05:44 UTC
✓ Verified
Current Version
f4eeb3c4853c2e7b5cc7afd42afc628de37a9db9e433c4efa1c5b78e35271628
May 6, 2026 05:48 UTC
✓ Verified
Change Detected
May 6, 2026 05:48 UTC
Analysis Methodology
✓ Verified
Source Document
https://substack.com/privacy
Citation Record
Entity: Substack
Document: Substack Privacy Policy
Record ID: CA-C-001699
Captured: 2026-05-06 05:48:17 UTC
URL: https://conductatlas.com/change/2026-05-06-substack-substack-privacy-policy-1699/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
For legal and compliance teams

Institutional Analysis

Assessment

Substack added a disclosure that account identifiers are shared with child safety consortia for CSAM detection. This is a transparency update, not a substantive change to data handling. The disclosure aligns with regulatory expectations under COPPA (which governs child safety online) and general FTC guidance on material changes to privacy practices. No new substantive obligations appear to be created by this disclosure alone; rather, it documents an existing practice.

Regulatory Exposure

COPPA (Children's Online Privacy Protection Act), FTC Act Section 5 (unfair or deceptive practices)

Full compliance analysis

Obligation analysis, escalation trigger, board language, and recommended action.

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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-001699.

Full Changes

See the full side-by-side comparison of every sentence added, removed, and modified.

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Document Context

Version history → Policy drift analysis → Document page →
Document
Substack Privacy Policy
Entity
Substack
Captured
May 6, 2026
Source URL
https://substack.com/privacy
Other changes to Substack Privacy Policy
Previous change May 5, 2026
Substack updated its privacy policy on May 5, 2026 to disclose that it shares account identifiers with child safety organizations …
Medium Neutral
View full version history →
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