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

OpenAI must bind Sub-Processors to de-identification obligations

Common · 280 of 343 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

How other platforms handle this

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Processor shall take reasonable steps to ensure the reliability of any employee, agent or contractor ... ensuring in each case that access is strictly limited to those individuals who need to know / access the relevant Customer Personal Data

Kling AI

The Company collect and process personal information in [Singapore, Malaysia] for the purpose of providing the services.

TikTok Ads

If you send us, or enable us to collect, Business Products Data...you agree to the Business Products (Data) Terms.

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
before sharing de-identified data with any other party, including Sub-Processors, contractually obligate any such recipients to comply with the requirements of this provision (c)(i)-(iii)...

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-061545
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-061545
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-061545/openai-must-bind-sub-processors-to-de-identification-obligations/
Accessed: Nov. 10, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Categories

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Frequently Asked Questions

What does OpenAI's OpenAI must bind Sub-Processors to de-identification obligations clause do?

The clause states: “before sharing de-identified data with any other party, including Sub-Processors, contractually obligate any such recipients to comply with the requirements of this provision (c)(i)-(iii)...”

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 280 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.