OpenAI · OpenAI Sub-Processor List · View original document ↗

Microsoft cloud infrastructure processes customer data

High severity Medium confidence Explicitdocumentlanguage Common · 290 of 352 platforms
Share 𝕏 Share in Share 🔒 PDF
Recent governance activity OpenAI recorded 16 documented changes in the last 30 days.
Start monitoring updates
Monitor governance changes for OpenAI Create a free account to receive the weekly governance digest and monitor one platform for governance changes.
Create free account No credit card required.

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)

Customer data processed through Microsoft's cloud infrastructure may be handled in any of 22 countries, each with different data protection regimes, significantly broadening the geographic scope of data exposure.

Interpretive note: The excerpt does not specify which OpenAI services use Microsoft cloud infrastructure or which categories of customer data are affected. Country list is taken as stated but the full service scope is not determinable from the excerpt alone.

Consumer impact (what this means for users)

Your data processed through OpenAI's Microsoft cloud infrastructure may be handled in any of the 22 listed countries.

How other platforms handle this

Zoom Medium

Meeting and call recordings (if saved to the cloud by Customer Transcriptions of meeting or call recordings (if meeting recorded and saved to the cloud by Customer)

Squarespace Medium

Each payment processor uses and processes your complete payment information in accordance with its applicable privacy policy (Stripe and PayPal).

Lime Medium

if you are accessing and using Lime Services under a corporate account...you acknowledge and agree that Lime may share certain of your usage information with whomever provided you with access to the Lime Services

See all platforms with this clause type →

Monitoring

OpenAI has changed this document before.

Receive same-day alerts, structured change summaries, and monitoring for up to 25 platforms.

Get Monitor Or create a free account →
▸ View Original Clause Language DOCUMENT RECORD
"
Microsoft Corporation ... Australia Brazil Canada France Germany India Indonesia Ireland Italy Japan Mexico Netherlands Norway Poland Singapore South Africa South Korea Spain Sweden Switzerland United Arab Emirates United Kingdom United States Cloud infrastructure

— Excerpt from OpenAI's OpenAI Sub-Processor List

Applicable regulations

BIPA
Illinois, USA
CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
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 Sub-Processor List
Entity
OpenAI
Document last updated
July 6, 2026
Tracking information
First tracked
July 6, 2026
Last verified
July 9, 2026
Record ID
CA-P-069948
Document ID
CA-D-00928
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
a031cf75d704b4e3de0cedb3ff0a622f189068f774fcde7f6f76c2a0b6251ac3
Analysis generated
July 6, 2026 23:01 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: OpenAI
Document: OpenAI Sub-Processor List
Record ID: CA-P-069948
Captured: 2026-07-06 23:01:36 UTC
SHA-256: a031cf75d704b4e3…
URL: https://conductatlas.com/platform/openai/openai-sub-processor-list/provision/CA-P-069948/microsoft-cloud-infrastructure-processes-customer-data/
Accessed: July 12, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

Other risks in this policy

Related Analysis

Compliance Governance Intelligence

Need to monitor specific governance provisions?

Compliance includes provision-level monitoring, governance timelines, regulatory mapping, and audit-ready analysis.

Arbitration clauses AI governance Data rights Indemnification Retention policies
Get Compliance

Or start with Monitor →

Built from archived source documents, structured governance mappings, and historical version tracking.

Frequently Asked Questions

What does OpenAI's Microsoft cloud infrastructure processes customer data clause do?

Customer data processed through Microsoft's cloud infrastructure may be handled in any of 22 countries, each with different data protection regimes, significantly broadening the geographic scope of data exposure.

How does this clause affect you?

Your data processed through OpenAI's Microsoft cloud infrastructure may be handled in any of the 22 listed countries.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.

Is ConductAtlas affiliated with OpenAI?

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