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

Sub-Processors process Customer Data only as necessary for Services

Medium severity Explicit document language Common · 279 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

How other platforms handle this

Square Medium

we may use this information to make it easier for you to find the people you want to send payments to, for account and identity verification and fraud prevention purposes, to reduce the risk you will send payments to the wrong person, or to provide other personalized services.

Google Cloud Medium

We evaluate Service Data to help us improve the performance and functionality of Cloud Services.

MyFitnessPal Medium

We use your personal information to send you newsletters and other promotional communications, including information about MyFitnessPal's new offerings, features, offers, events, webinars, and other information.

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
Sub-Processors will Process Customer Data as necessary to perform the Services. Such Processing will be for the duration of the Agreement, unless otherwise agreed in writing.

Excerpt from OpenAI's Data Processing Addendum

Applicable regulations

EU AI Act
European Union
BIPA
Illinois, USA
CCPA/CPRA
California, USA
Colorado AI Act
US-CO
CAN-SPAM
United States Federal
ePrivacy Directive
European Union
EU AI Act - High Risk Provisions
EU
FTC Act Section 5
United States Federal
GDPR
European Union
UK GDPR
United Kingdom

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-061570
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-061570
Captured: 2026-07-09 03:35:12 UTC
SHA-256: 3a1b6bc316e690b8…
URL: https://conductatlas.com/platform/openai/openai-data-processing-addendum/provision/CA-P-061570/sub-processors-process-customer-data-only-as-necessary-for-services/
Accessed: Aug. 7, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does OpenAI's Sub-Processors process Customer Data only as necessary for Services clause do?

The clause states: “Sub-Processors will Process Customer Data as necessary to perform the Services. Such Processing will be for the duration of the Agreement, unless otherwise agreed in writing.”

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 279 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.