CA-C-002116
Substack — Substack Privacy Policy
Entity
Date detected
May 15, 2026
Effective date
May 15, 2026
Severity
Low
Direction
Neutral
Affected users
all users
Taxonomy
Data collection expansion
Changes
+3 sentences added · 1 sentence modified
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Event Summary

Substack updated its privacy policy on May 15, 2026 to disclose that it shares account identifiers with child safety industry consortia and now receives information from those consortia to detect child sexual abuse material (CSAM). The policy also added language stating that Substack may obtain additional information from third parties, combine it with platform data, and use the combined information to provide safer experiences and improve the platform and analytics.

LOW

Consumer Impact

The updated policy discloses that Substack shares account identifiers with child safety industry consortia and receives information from those consortia to detect CSAM. The policy now also states that Substack may obtain additional information from third parties and combine it with platform data to provide safer experiences and improve platform analytics. The updated terms treat combined information from other sources in accordance with the overall privacy policy. These are disclosures of existing or new data-handling practices rather than changes that grant users new control mechanisms.

Governance Analysis

The updated policy establishes explicit disclosure of data sharing with child safety consortia and third-party data integration practices. These disclosures clarify how Substack processes account identifiers and other information for safety purposes and platform improvement, which affects what data handling users should expect when using the platform.

Key Clauses Affected

Child Safety Data Sharing Disclosure

Policy now states Substack shares account identifiers with and receives information from child safety industry consortia to detect CSAM.

Third-Party Data Integration

Policy adds that Substack may obtain information from third parties, combine it with platform data, and use combined information for safety and analytics purposes.

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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
f4eeb3c4853c2e7b5cc7afd42afc628de37a9db9e433c4efa1c5b78e35271628
May 6, 2026 05:48 UTC
✓ Verified
Current Version
adf9071a57481f4c514405aceec0e941e6526a12e5e33acce8ea0d954b33ccc9
May 15, 2026 00:21 UTC
✓ Verified
Change Detected
May 15, 2026 00:21 UTC
Analysis Methodology
✓ Verified
Source Document
https://substack.com/privacy
Citation Record
Entity: Substack
Document: Substack Privacy Policy
Record ID: CA-C-002116
Captured: 2026-05-15 00:21:27 UTC
URL: https://conductatlas.com/change/2026-05-15-substack-substack-privacy-policy-2116/
Accessed: May 20, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
For legal and compliance teams

Institutional Analysis

Assessment

Substack disclosed two changes to its data-handling practices on May 15, 2026: bidirectional data sharing with child safety consortia for CSAM detection, and third-party data integration for safety and analytics purposes. The CSAM disclosure aligns with industry practice and regulatory expectations under NCMEC standards and FOSTA-SESTA frameworks. The third-party data integration disclosure appears standard for content platforms. No material compliance obligation changes are created by the disclosure itself, but organizations that serve Substack users should evaluate whether their own privacy notices adequately reflect that platform data may be combined with third-party sources before use in their systems.

Regulatory Exposure

FOSTA-SESTA (US federal law requiring platforms to report CSAM and develop detection programs), NCMEC CyberTipline protocols, COPPA (if minors are users), GDPR Article 6 (lawful basis for processing) and Article 14 (information to be provided where data not obtained from data subject), CCPA (California residents' right to know sources of personal information), state child safety laws (varying by jurisdiction).

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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-002116.

Full Changes

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Document Context

Version history → Policy drift analysis → Document page →
Document
Substack Privacy Policy
Entity
Substack
Captured
May 15, 2026
Source URL
https://substack.com/privacy
Other changes to Substack Privacy Policy
Previous change May 6, 2026
Substack's privacy policy now discloses that the company shares account identifiers with child safety industry consortia to detect child sexual …
Low Positive
Next change May 19, 2026
The navigation footer of Substack's privacy policy page was updated on May 19, 2026 to include comparative product links. Specifically, …
Low Neutral
View full version history →
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