Provision record
OpenAI · OpenAI Privacy Policy · View original document ↗

Data Retention After Deletion Requests

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Document Record

What it is

The policy states that deletion requests result in data removal within 30 days, subject to multiple retention carve-outs including legal obligations, fraud and abuse purposes, security reasons, financial record-keeping, and retention of data from banned accounts. Additionally, data already de-identified and used for model training prior to deletion is not subject to the 30-day deletion commitment.

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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 provision establishes the conditions under which OpenAI will not fulfill a deletion request within the standard 30-day window, including a broadly stated 'fraud and abuse' carve-out applicable to banned accounts. The de-identification exception for model training data means that content contributed to model training prior to deletion may persist in model weights or training datasets even after account deletion.

Recent Activity

This document changed recently

Medium Jun 12, 2026

The updated policy explicitly discloses that OpenAI receives information from advertisers and other data partners for Free and Go users, and uses this data to personalize ads and measure ad effectiveness. The policy now states that Free and Go users can control what data OpenAI uses to personalize ads through advertising controls in account settings. This represents clarified disclosure of an existing practice rather than a new authorization.

View change record →
Medium Jun 7, 2026

The updated privacy policy now explicitly states that OpenAI receives information from advertisers and other data partners, which is used to personalize ads shown to Free and Go users and to measure the effectiveness of those ads. For example, the policy notes that OpenAI could receive information about purchases users make from advertisers. The policy now includes a dedicated section on ad personalization and measurement as a primary use of personal data for these user tiers. You can manage what data OpenAI uses for ad personalization by accessing the advertising controls in your account settings or by using the Data Controls option.

View change record →
Medium May 1, 2026

The updated policy now explicitly authorizes OpenAI to promote products and services to users through direct marketing on third-party properties and to share limited information with select marketing partners (who are not service providers) to support these efforts. The policy states that some marketing partners may receive information through cookies and similar technologies. The revised terms establish that these marketing practices are subject to user choices and controls, with additional information and opt-out options available. You can make choices about the use of your information for third-party product promotion purposes through controls referenced in the policy.

View change record →

Consumer impact (what this means for users)

Under this provision, a deletion request will be processed within 30 days unless one of several carve-outs applies, including fraud, security, legal obligations, or financial record-keeping. Content that was de-identified and used for model training prior to a deletion request may not be retrievable or removable, as the policy states OpenAI will not attempt to re-identify de-identified data.

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.
  • Delete Your Data
    Submit a deletion request at privacy.openai.com or by emailing dsar@openai.com. You can also delete your account directly through ChatGPT account settings. OpenAI states removal occurs within 30 days subject to the policy's retention carve-outs.

Cross-platform context

See how other platforms handle Data Retention After Deletion Requests and similar clauses.

Compare across platforms →
▸ View Original Clause Language DOCUMENT RECORD
"
Once you choose to delete Personal Data, we will remove it from our systems within 30 days unless we need to retain it for longer as described below, or it has already been de-identified and disassociated from your account when you allow us to use your Content to improve our models. ... In some cases, we need to retain Personal Data for longer even after you delete it, for example because we are legally required to, to address fraud and abuse, for security reasons, or for financial record-keeping purposes. For instance: If specific Content, or your account, is banned because of violations of our usage policies, we may retain that data for to protect our services from fraud, abuse, or other violations of our policies.

Excerpt from OpenAI's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

(1) REGULATORY LANDSCAPE: CCPA and CPRA provide California residents with a right to deletion subject to enumerated exceptions; compliance teams should assess whether the carve-outs described in this policy align with the statutory exceptions under …

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • FTC
    The FTC has jurisdiction over consumer privacy practices including the adequacy of data deletion mechanisms and the scope of retention exceptions claimed by companies.
    File a complaint →
  • State AG
    State attorneys general in California and other states with statutory deletion rights have enforcement authority over the scope and adequacy of deletion practices and carve-outs.
    File a complaint →

Provision details

Document information
Document
OpenAI Privacy Policy
Entity
OpenAI
Document last updated
May 5, 2026
Tracking information
First tracked
Sept. 11, 2026
Last verified
Sept. 11, 2026
Record ID
CA-P-077392
Document ID
CA-D-00010
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
8ee232ad6c110b02c18d379ad054ed5a418f8064056cc5138741afff26158d34
Analysis generated
September 11, 2026 01:57 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: OpenAI
Document: OpenAI Privacy Policy
Record ID: CA-P-077392
Captured: 2026-09-11 01:57:58 UTC
SHA-256: 8ee232ad6c110b02…
URL: https://conductatlas.com/platform/openai/openai-privacy-policy/provision/CA-P-077392/data-retention-after-deletion-requests/
Accessed: Sept. 27, 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 Data Retention After Deletion Requests clause do?

This provision establishes the conditions under which OpenAI will not fulfill a deletion request within the standard 30-day window, including a broadly stated 'fraud and abuse' carve-out applicable to banned accounts. The de-identification exception for model training data means that content contributed to model training prior to deletion may persist in model weights or training datasets even after account deletion.

How does this clause affect you?

Under this provision, a deletion request will be processed within 30 days unless one of several carve-outs applies, including fraud, security, legal obligations, or financial record-keeping. Content that was de-identified and used for model training prior to a deletion request may not be retrievable or removable, as the policy states OpenAI will not attempt to re-identify de-identified data.

Is ConductAtlas affiliated with OpenAI?

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