OpenAI · OpenAI Data Processing Addendum · View original document ↗

Sub-Processor Authorization and Notification

Medium severity Medium confidence Explicitdocumentlanguage Unique · 0 of 325 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 clause establishes the procedural framework governing third-party processor engagement under data protection regulations. It conditions sub-processor use on advance notification and creates a structured objection process rather than requiring affirmative approval for each processor change.

Interpretive note: The adequacy of the general authorization and notification mechanism under GDPR Article 28(2) may be subject to different interpretations by individual EU supervisory authorities.

Consumer impact (what this means for users)

Customers receive notification of sub-processor changes and retain the ability to object in writing within the specified period. If no objection is submitted within the timeframe specified in the notification, the sub-processor authorization proceeds as stated in the terms.

How other platforms handle this

Glean Medium

We use third-party service providers (sub-processors) to help us provide our services. These sub-processors may have access to personal data only as necessary to perform their functions. We maintain a list of sub-processors and will notify enterprise customers of material changes in accordance with ...

TikTok Medium

To make the Platform more relevant and enjoyable for you, we customize parts of your experience on the Platform to show you creators and content we think you will be interested in, including ads and other content sponsored by or in collaboration with our creators and our partners. We customize what ...

Snapchat Medium

We collect information from and about the third parties you link to your account and from other sources, including from other Snap users and third parties, to provide services and personalize your experience... We also infer information about you based on what we observe... This can include inferenc...

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▸ View Original Clause Language DOCUMENT RECORD
"
Customer provides a general authorization to OpenAI to engage sub-processors. OpenAI will notify Customer of any changes to its sub-processors (including additions or replacements) by updating the sub-processor list available on OpenAI's website or by notifying Customer directly. Customer may object to any new sub-processor within the period specified in the notification by providing written notice to OpenAI.

— Excerpt from OpenAI's OpenAI 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
May 11, 2026
Last verified
May 12, 2026
Record ID
CA-P-010687
Document ID
CA-D-00757
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
8ae5b556815e67cd00740a6c1b656c2b56a01dfecbb0b039a8fa2625f2c769ba
Analysis generated
May 11, 2026 13:05 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: OpenAI
Document: OpenAI Data Processing Addendum
Record ID: CA-P-010687
Captured: 2026-05-11 13:05:56 UTC
SHA-256: 8ae5b556815e67cd…
URL: https://conductatlas.com/platform/openai/openai-data-processing-addendum/sub-processor-authorization-and-notification/
Accessed: May 20, 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-Processor Authorization and Notification clause do?

This clause establishes the procedural framework governing third-party processor engagement under data protection regulations. It conditions sub-processor use on advance notification and creates a structured objection process rather than requiring affirmative approval for each processor change.

How does this clause affect you?

Customers receive notification of sub-processor changes and retain the ability to object in writing within the specified period. If no objection is submitted within the timeframe specified in the notification, the sub-processor authorization proceeds as stated in the terms.

Is ConductAtlas affiliated with OpenAI?

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