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
The notification obligation triggers the customer's own breach notification timelines under GDPR (72 hours to supervisory authorities) and other regulations. The timeliness and completeness of OpenAI's notification directly affects the customer's ability to meet its own legal obligations.
Interpretive note: The 'without undue delay' standard does not specify a fixed timeframe, which may create ambiguity about whether OpenAI's notification timing is sufficient to support the customer's GDPR Article 33 72-hour obligation.
This document primarily affects businesses using the OpenAI API rather than individual ChatGPT consumers, governing how personal data about individuals processed through those business products is handled. The agreement states that OpenAI will not sell or share personal data submitted via the API, will assist operators in responding to data subject access, deletion, and correction requests, and will delete or return personal data upon termination. You can contact the operator (the business whose product you use) to exercise data subject rights such as access or deletion, as the DPA assigns responsibility for handling those requests to the operator in the first instance.
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"OpenAI will notify Customer without undue delay after becoming aware of a Security Incident affecting Customer Personal Data. OpenAI will provide information about the Security Incident as it becomes available, including the nature of the Security Incident, the categories and approximate number of data subjects concerned, the categories and approximate number of personal data records concerned, and the measures taken or proposed to address the Security Incident.— Excerpt from OpenAI's OpenAI Data Processing Addendum
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The notification obligation triggers the customer's own breach notification timelines under GDPR (72 hours to supervisory authorities) and other regulations. The timeliness and completeness of OpenAI's notification directly affects the customer's ability to meet its own legal obligations.
ConductAtlas has identified this type of provision across 1 platforms. See the full comparison.
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