The document states that fine-tuned models created using customer data are exclusive to the customer and are not shared or used to train other models, and that fine-tuning data is retained until the customer actively deletes the files.
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 that fine-tuning data has an indefinite retention period by default, persisting until the customer deletes the files, which differs from the 30-day default retention period applicable to standard API inputs and outputs.
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 →This new provision addresses a specific use case with distinct data handling practices, guaranteeing model exclusivity and customer-controlled data retention for fine-tuned models.
View full change record →Under this provision, data submitted for model fine-tuning is retained on OpenAI systems indefinitely until the customer takes affirmative action to delete the files. Customers intending to limit fine-tuning data retention must actively manage and delete files through the platform.
Cross-platform context
See how other platforms handle Fine-Tuning Data Retention and Model Exclusivity and similar clauses.
Compare across platforms →"Yes, you can adapt certain models to specific tasks by fine-tuning them with your own prompt-completion pairs. Your fine-tuned models are for your use alone and never served to or shared with other customers or used to train other models. Data submitted to fine-tune a model is retained until the customer deletes the files.Excerpt from OpenAI's API Data Usage Policies [RETIRED: redirects to /enterprise-privacy/ (CA-D-000825)]
(1) REGULATORY LANDSCAPE: This provision engages GDPR storage limitation principles under Article 5(1)(e), which requires that personal data be retained no longer than necessary for the stated processing purpose.
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This provision establishes that fine-tuning data has an indefinite retention period by default, persisting until the customer deletes the files, which differs from the 30-day default retention period applicable to standard API inputs and outputs.
Under this provision, data submitted for model fine-tuning is retained on OpenAI systems indefinitely until the customer takes affirmative action to delete the files. Customers intending to limit fine-tuning data retention must actively manage and delete files through the platform.
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