The document states that OpenAI does not use business customer data for model training by default, but reserves the right to train on data if the customer has explicitly opted in through available opt-in mechanisms.
This analysis describes what OpenAI's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision establishes a default data protection posture for enterprise customers, but the opt-in mechanism and what constitutes valid opt-in consent are not fully detailed within this document, requiring review of supplemental terms and the specific opt-in interface presented to customers.
Interpretive note: The document does not specify the format, location, or revocability conditions of the opt-in mechanism, creating ambiguity about whether consent captured meets GDPR or other jurisdiction-specific standards.
The updated policy now states that workspace admins 'can control' data retention rather than 'control' it, introducing subtle ambiguity about whether retention control is a guaranteed right or a permitted option. Additionally, the removal of the word 'workspace' before 'data' broadens the scope of data potentially subject to admin control beyond workspace-specific information. These changes could affect how enterprise customers understand the extent of their administrative authority over data retention practices.
View change record →The updated terms establish that workspace admins, rather than individual end users, control how long workspace conversation data is retained and authorize admins to view, access, export, and delete end user conversations. Previously, the policy stated that each user controlled whether their conversations were retained and that only end users could view their own conversations. The revised terms also permit OpenAI to retain deleted or unsaved conversations beyond the standard 30-day deletion window if retention is required by law or reasonably necessary to protect OpenAI's services or third parties from harm. Workspace users should review their organization's data governance policies to understand what access and retention practices their admins have implemented.
View change record →Current version provides more specific examples of opt-in mechanisms (feedback mechanisms) and clarifies the purpose is to 'improve our services'.
View full change record →Under this provision, business data submitted through covered products is not used for model training unless the customer actively opts in. The agreement does not specify in this document the precise mechanism or interface through which opt-in consent is recorded, which may require independent verification by enterprise customers.
Cross-platform context
See how other platforms handle Default No-Training Commitment with Opt-In Exception and similar clauses.
Compare across platforms →"By default, we do not use your business data for training our models. If you have explicitly opted in to share your data with us (for example, through our opt-in feedback mechanisms) to improve our services, then we may use the shared data to train our models.Excerpt from OpenAI's API Data Usage Policies [RETIRED: redirects to /enterprise-privacy/ (CA-D-000825)]
(1) REGULATORY LANDSCAPE: This provision engages GDPR Article 6 lawful basis requirements and GDPR Article 7 consent standards, particularly regarding the specificity and freely given nature of opt-in consent for data processing beyond the original …
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This provision establishes a default data protection posture for enterprise customers, but the opt-in mechanism and what constitutes valid opt-in consent are not fully detailed within this document, requiring review of supplemental terms and the specific opt-in interface presented to customers.
Under this provision, business data submitted through covered products is not used for model training unless the customer actively opts in. The agreement does not specify in this document the precise mechanism or interface through which opt-in consent is recorded, which may require independent verification by enterprise customers.
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