OpenAI · OpenAI Enterprise Privacy · View original document ↗

No Training on Enterprise and API Data by Default

Medium severity Medium confidence Explicitdocumentlanguage Unique · 0 of 343 platforms
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Document Record

What it is

OpenAI states that data you submit through the API, ChatGPT Enterprise, or ChatGPT Team products is not used to train its AI models unless you separately opt in.

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 provision directly addresses one of the most common concerns for enterprise customers: whether their proprietary data, client information, or confidential inputs could be incorporated into OpenAI's model training. The document states this does not happen by default for these specific product tiers.

Interpretive note: The commitment is stated on a marketing/disclosure page rather than in a formally executed contractual instrument, and enforceability depends on the operative Terms of Service and any executed DPA.

Consumer impact (what this means for users)

Enterprise and API customers' inputs and outputs are stated to be excluded from model training by default, which may be material for organizations submitting confidential, proprietary, or regulated data through these products.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Export Your Data
    Contact OpenAI enterprise sales to request and execute a Data Processing Addendum that contractually reflects the no-training commitment for your organization.

How other platforms handle this

Strava Medium

We use information to enhance the quality, reliability, and/or accuracy of our AI Features by creating, developing, training, testing, improving, and maintaining AI and ML models run by Strava or our service providers. We use aggregated, de-identified data for this purpose. We also use personal info...

Ledger Medium

At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.

Garmin Medium

If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to access, correct, or erase your personal data; the right to restrict or object to our processing of your personal data; the right to data portability; and, where our processing is based on your...

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▸ View Original Clause Language DOCUMENT RECORD
"
We do not train on your business data by default. Inputs and outputs through the API and in ChatGPT Enterprise and ChatGPT Team are not used to train our models by default.

— Excerpt from OpenAI's OpenAI Enterprise Privacy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: This provision engages GDPR principles of purpose limitation and data minimization, as well as CCPA provisions regarding use of personal information beyond the disclosed purpose. The FTC's authority over unfair and deceptive practices is relevant if the stated commitment is not operationally implemented as described. No specific GDPR article is cited in the document, but the commitment aligns with Article 5 purpose limitation principles. GOVERNANCE EXPOSURE: Medium. The commitment is stated clearly but its enforceability depends on whether it is reflected in an executed DPA or Terms of Service rather than a marketing disclosure page alone. If a customer has not executed a DPA, the operative Terms of Service govern, and compliance teams should verify consistency between the two instruments. JURISDICTION FLAGS: EU/EEA customers have heightened exposure because GDPR imposes binding obligations on data processors, and a marketing-page commitment may not satisfy the Article 28 written processor agreement requirement. California customers may evaluate this commitment against CCPA service provider restrictions on secondary use of personal information. CONTRACT AND VENDOR IMPLICATIONS: Procurement teams should confirm this commitment is reflected verbatim or by reference in the executed DPA or enterprise agreement, as a webpage disclosure is not a contractual guarantee. Vendor assessments should include verification of the technical mechanisms by which training exclusion is implemented. COMPLIANCE CONSIDERATIONS: Compliance teams should map this commitment against their data processing records, update vendor assessments to reflect the no-training commitment, and confirm that any sub-processors OpenAI uses are subject to equivalent restrictions. Where the DPA is not yet executed, this should be treated as a due diligence gap.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC has authority over unfair or deceptive practices and could evaluate whether OpenAI's stated data handling commitments are implemented as described.
    File a complaint →

Applicable regulations

EU AI Act
European Union
BIPA
Illinois, USA
CCPA/CPRA
California, USA
Colorado AI Act
US-CO
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
EU AI Act - High Risk Provisions
EU
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 Enterprise Privacy
Entity
OpenAI
Document last updated
May 12, 2026
Tracking information
First tracked
May 12, 2026
Last verified
May 12, 2026
Record ID
CA-P-011968
Document ID
CA-D-00825
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
ac048cebc19346f5fd75309f8820fd04c36648bc8cece90f5edd62740c55d0de
Analysis generated
May 12, 2026 16:41 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: OpenAI
Document: OpenAI Enterprise Privacy
Record ID: CA-P-011968
Captured: 2026-05-12 16:41:02 UTC
SHA-256: ac048cebc19346f5…
URL: https://conductatlas.com/platform/openai/openai-enterprise-privacy/no-training-on-enterprise-and-api-data-by-default/
Accessed: June 28, 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 No Training on Enterprise and API Data by Default clause do?

This provision directly addresses one of the most common concerns for enterprise customers: whether their proprietary data, client information, or confidential inputs could be incorporated into OpenAI's model training. The document states this does not happen by default for these specific product tiers.

How does this clause affect you?

Enterprise and API customers' inputs and outputs are stated to be excluded from model training by default, which may be material for organizations submitting confidential, proprietary, or regulated data through these products.

Is ConductAtlas affiliated with OpenAI?

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