Provision record
OpenAI · OpenAI Data Processing Addendum · View original document ↗

OpenAI processes data only per Customer Instructions

High confidence Common · 273 of 343 platforms

Key Facts · in the document’s own words

When will OpenAI process Customer Data only in accordance with Customer Instructions?
“OpenAI will process Customer Data only in accordance with Customer Instructions, unless required to do so by applicable law to which OpenAI is subject...”
Version CA-V-005936, captured Aug. 20, 2026 · live source ↗
Our reading, not the document’s words
OpenAI will process Customer Data only in accordance with Customer Instructions, unless required to do so by applicable law to which OpenAI is subject.
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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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

Generated by a model from the captured document; not read by a person

This clause establishes Customer control over data processing as the default, with the only override being a legal obligation imposed on OpenAI—limiting OpenAI's discretion to use Customer Data for other purposes.

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Interpretive note: The excerpt is truncated; any further elaboration on the scope of 'Customer Instructions' or the legal override is not captured.

Consumer impact (what this means for users)

Generated by a model from the captured document; not read by a person

Customers can expect their Customer Data to be processed only as they instruct, with the exception that applicable law binding OpenAI may require different processing.

How other platforms handle this

Cloudflare

To the extent the Network Data includes any Personal Data...Cloudflare will handle such Personal Data in compliance with applicable data protection laws.

Palantir

To the extent we treat data as deidentified under the US State Privacy Laws, we will maintain and use that data solely in deidentified form and will not attempt to reidentify that data with any individuals, other than to assess whether the deidentification process complies with applicable law...

Kling AI

We process your data for necessary purposes as described in the main Policy, and for secondary purposes. We use both human and automated means to process your data.

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
OpenAI will process Customer Data only in accordance with Customer Instructions, unless required to do so by applicable law to which OpenAI is subject...

Excerpt from OpenAI's Data Processing Addendum

Provision details

Document information
Document
OpenAI Data Processing Addendum
Entity
OpenAI
Date stated by the document
Jan. 1, 2026
As printed in OpenAI’s text (version CA-V-005936), not a ConductAtlas date.
Tracking information
First captured by ConductAtlas
May 11, 2026
Text quoted from version
CA-V-005936, captured Aug. 20, 2026
Record ID
CA-P-061465
Document ID
CA-D-000757
Evidence Provenance
Source URL
Wayback Machine
Extracted-text SHA-256 (version CA-V-005936)
3576c9c2da3364bebf36269c4340b36cad2c77854aec7ec441aa394207198c93
Analysis generated
July 9, 2026 03:35 UTC
Methodology
Evidence
✓ Excerpt found in version CA-V-005936, captured Aug. 20, 2026 (checked Oct. 5, 2026)
Citation Record
Entity: OpenAI
Document: OpenAI Data Processing Addendum
Record ID: CA-P-061465
Version: CA-V-005936
Captured: 2026-08-20 00:04:53 UTC
SHA-256: 3576c9c2da3364be…
URL: https://conductatlas.com/platform/openai/openai-data-processing-addendum/provision/CA-P-061465/openai-processes-data-only-per-customer-instructions/
Accessed: Nov. 4, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Categories

Other risks in this policy

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Frequently Asked Questions

What does OpenAI's OpenAI processes data only per Customer Instructions clause do?

This clause establishes Customer control over data processing as the default, with the only override being a legal obligation imposed on OpenAI—limiting OpenAI's discretion to use Customer Data for other purposes.

How does this clause affect you?

Customers can expect their Customer Data to be processed only as they instruct, with the exception that applicable law binding OpenAI may require different processing.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 273 platforms. See the full comparison.

Is ConductAtlas affiliated with OpenAI?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by OpenAI.