OpenAI · OpenAI Data Processing Addendum · View original document ↗

EEA and Swiss Data international transfers require SCCs or adequacy decision

High severity Medium confidence Explicitdocumentlanguage Common · 290 of 352 platforms
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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)

This establishes the legal mechanism OpenAI Ireland Limited uses to legitimize international transfers of EEA and Swiss Data, which is a core requirement under European data protection law.

Interpretive note: The excerpt is truncated after 'SCCs'; the reference to adequacy decisions is inferred from standard SCC transfer framework language and is noted in omitted_material. Confidence is medium because the full alternative bases are not fully quoted.

Consumer impact (what this means for users)

EEA and Swiss Data transferred by OpenAI Ireland Limited outside the EEA or Switzerland is protected by Standard Contractual Clauses or, where applicable, an adequacy decision.

How other platforms handle this

Adobe Medium

we also transfer personal information to all other countries in which Adobe or its affiliates, providers, and partners operate. We carry out these transfers in compliance with applicable laws – for example, by putting data transfer agreements in place...

Squarespace Medium

Each payment processor uses and processes your complete payment information in accordance with its applicable privacy policy (Stripe and PayPal).

Lime Medium

if you are accessing and using Lime Services under a corporate account...you acknowledge and agree that Lime may share certain of your usage information with whomever provided you with access to the Lime Services

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▸ View Original Clause Language DOCUMENT RECORD
"
To the extent OpenAI Ireland Limited transfers EEA and Swiss Data to other OpenAI Affiliates or third parties outside the European Economic Area or Switzerland...it will do so on the basis of agreements containing SCCs...

— Excerpt from OpenAI's OpenAI Data Processing Addendum

Applicable regulations

BIPA
Illinois, USA
CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
UK GDPR
United Kingdom
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
OpenAI Data Processing Addendum
Entity
OpenAI
Document last updated
May 11, 2026
Tracking information
First tracked
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-061534
Document ID
CA-D-00757
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
3a1b6bc316e690b84874f1ab6de51ac037a8084441b88c58ba8dec245e06e17d
Analysis generated
July 9, 2026 03:35 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: OpenAI
Document: OpenAI Data Processing Addendum
Record ID: CA-P-061534
Captured: 2026-07-09 03:35:12 UTC
SHA-256: 3a1b6bc316e690b8…
URL: https://conductatlas.com/platform/openai/openai-data-processing-addendum/provision/CA-P-061534/eea-and-swiss-data-international-transfers-require-sccs-or-adequacy-decision/
Accessed: July 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does OpenAI's EEA and Swiss Data international transfers require SCCs or adequacy decision clause do?

This establishes the legal mechanism OpenAI Ireland Limited uses to legitimize international transfers of EEA and Swiss Data, which is a core requirement under European data protection law.

How does this clause affect you?

EEA and Swiss Data transferred by OpenAI Ireland Limited outside the EEA or Switzerland is protected by Standard Contractual Clauses or, where applicable, an adequacy decision.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 290 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.