OpenAI commits that its staff and others who access API customer personal data are bound by confidentiality obligations, either by contract or by law.
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 implements a standard GDPR Article 28(3)(b) requirement and provides operators with a contractual assurance that internal access to their data is subject to confidentiality controls. It does not specify the scope of access logging or auditing.
Personal data submitted through the API is accessed only by individuals who are contractually or legally obligated to keep it confidential, according to the terms of this DPA.
How other platforms handle this
If you are in the European Economic Area (EEA), we only process your personal data when we have a valid legal basis to do so, including when: (a) you have consented to the processing; (b) the processing is necessary to perform a contract with you; (c) we have a legitimate interest in processing your...
We process the information you share with us when you create your profile or send messages. This includes photos, videos, messages, and other content you share on the platform. We may use this content to improve our services, ensure safety, and comply with legal obligations.
At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.
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"OpenAI will ensure that persons authorized to process Customer Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.— Excerpt from OpenAI's OpenAI Data Processing Addendum
REGULATORY LANDSCAPE: GDPR Article 28(3)(b) requires processor contracts to include confidentiality obligations for authorized persons. This provision satisfies that requirement. UK GDPR and Swiss nFADT impose equivalent obligations. GOVERNANCE EXPOSURE: Low. This is a standard processor contract requirement and does not create unusual compliance exposure. Operators may wish to request details about how OpenAI operationalizes this commitment (e.g. through employee agreements, access controls, or audit logging) as part of a security review. JURISDICTION FLAGS: Standard across GDPR, UK GDPR, and Swiss nFADT jurisdictions. No heightened jurisdictional exposure beyond standard processor contract requirements. CONTRACT AND VENDOR IMPLICATIONS: This provision is standard in cloud and AI service processor contracts. Procurement teams may request OpenAI's security documentation (SOC 2, ISO 27001 certifications, or equivalent) to confirm how confidentiality is operationally enforced beyond the contractual commitment. COMPLIANCE CONSIDERATIONS: Operators should include this DPA provision in their vendor security assessment documentation and may request copies of relevant certifications from OpenAI to support their own compliance records.
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This provision implements a standard GDPR Article 28(3)(b) requirement and provides operators with a contractual assurance that internal access to their data is subject to confidentiality controls. It does not specify the scope of access logging or auditing.
Personal data submitted through the API is accessed only by individuals who are contractually or legally obligated to keep it confidential, according to the terms of this DPA.
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