OpenAI · OpenAI Privacy Policy · View original document ↗

GDPR Data Subject Rights for EEA and UK Users

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Document Record

What it is

If you live in the EU or UK, you have formal legal rights to see, correct, delete, and export your OpenAI personal data, and to object to how it is processed.

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)

These rights are legally enforceable under GDPR and the UK GDPR, meaning EEA and UK users can compel OpenAI to respond to access, deletion, and portability requests within regulatory timeframes.

Recent Activity

This document changed recently

Medium May 5, 2026

The updated policy no longer explicitly states that OpenAI receives information from advertisers and other data partners for ad measurement and improvement, nor does it mention that users can control…

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…

Medium Apr 22, 2026

The updated policy removes explicit language describing how OpenAI shares personal data with marketing partners through cookies and similar technologies. The policy previously stated that 'some of th…

Consumer impact (what this means for users)

EEA and UK users can submit requests to access or delete their OpenAI data by contacting dsar@openai.com, with OpenAI obligated under GDPR to respond within one month of the request.

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
    Send an email to dsar@openai.com requesting access, correction, deletion, or portability of your personal data. Include your account email address and specify the nature of your request; OpenAI is required to respond within one month under GDPR.

How other platforms handle this

Smartsheet Medium

If you are located in the EEA or UK, you may have the following rights under applicable data protection law: the right to access your personal data; the right to rectify inaccurate personal data; the right to erasure of your personal data; the right to restrict processing of your personal data; the ...

Grammarly Medium

If you are located in the EEA, UK, or Switzerland, you have certain rights with respect to your personal information, including the right to access your personal data, to correct or delete your personal data, to restrict processing of your personal data, to data portability, and to object to process...

Runway Medium

In addition to the above rights, your local laws (including those in the EU, UK, Japan, California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Virginia, or Utah) may afford you f...

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▸ View Original Clause Language DOCUMENT RECORD
"
If you are located in the EEA or UK, you have the following rights under applicable data protection law: Access: You can request a copy of the personal data we hold about you. Correction: You can ask us to correct inaccurate data. Deletion: You can ask us to delete your personal data. Portability: You can request a machine-readable copy of your personal data. Restriction: You can ask us to restrict how we process your personal data. Objection: You can object to our processing of your personal data. Withdrawing consent: You can withdraw your consent at any time where we rely on consent as our legal basis.

— Excerpt from OpenAI's OpenAI Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

(1) REGULATORY LANDSCAPE: This provision reflects obligations under GDPR Articles 15-22 and the UK GDPR. Enforcement authorities include national Data Protection Authorities in each EU member state and the UK Information Commissioner's Office (ICO). OpenAI's lead supervisory authority in the EU is the Irish Data Protection Commission (DPC). Failure to honor data subject rights requests within statutory timeframes (one month, extendable by two months) constitutes a violation subject to regulatory action. (2) GOVERNANCE EXPOSURE: Medium. The policy discloses the rights but does not specify response timeframes or detail the process for verifying requester identity, which are operationally significant. Incomplete or delayed responses to data subject requests are a leading source of DPA complaints and regulatory investigations. (3) JURISDICTION FLAGS: All EEA member states and the UK are within scope. The Irish DPC is the lead supervisory authority for GDPR purposes given OpenAI's EU establishment. UK ICO jurisdiction applies separately post-Brexit. Non-EEA users (including US users) are not guaranteed these rights under the policy, though CCPA provides analogous rights for California residents. (4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers who route their users' data through OpenAI must ensure their own privacy notices accurately describe OpenAI's data subject rights mechanisms, and their data processing agreements with OpenAI should address how user data subject requests are handled at the sub-processor level. (5) COMPLIANCE CONSIDERATIONS: Legal teams should confirm that OpenAI's DSAR intake and response process is operationally compliant, including identity verification procedures, response tracking, and escalation paths to the Irish DPC; they should also verify that deletion requests result in removal from training data pipelines to the extent technically feasible.

Full compliance analysis

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

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Applicable agencies

  • State AG
    EU and UK data subjects can escalate unresolved DSAR complaints to their national Data Protection Authority or the UK ICO; the State_AG field is the closest available proxy for non-US regulatory bodies in this schema.
    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 Privacy Policy
Entity
OpenAI
Document last updated
May 5, 2026
Tracking information
First tracked
May 10, 2026
Last verified
May 10, 2026
Record ID
CA-P-009766
Document ID
CA-D-00010
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
9fedd919cc6d99e951ea6b8c198d3ded6d0673342d8c265778e44a35720b9b49
Analysis generated
May 10, 2026 22:24 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: OpenAI
Document: OpenAI Privacy Policy
Record ID: CA-P-009766
Captured: 2026-05-10 22:24:41 UTC
SHA-256: 9fedd919cc6d99e9…
URL: https://conductatlas.com/platform/openai/openai-privacy-policy/gdpr-data-subject-rights-for-eea-and-uk-users/
Accessed: May 14, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

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Frequently Asked Questions

What does OpenAI's GDPR Data Subject Rights for EEA and UK Users clause do?

These rights are legally enforceable under GDPR and the UK GDPR, meaning EEA and UK users can compel OpenAI to respond to access, deletion, and portability requests within regulatory timeframes.

How does this clause affect you?

EEA and UK users can submit requests to access or delete their OpenAI data by contacting dsar@openai.com, with OpenAI obligated under GDPR to respond within one month of the request.

Is ConductAtlas affiliated with OpenAI?

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