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

Moderation sharing limited to flagged content samples

High severity High confidence Explicitdocumentlanguage Common · 290 of 352 platforms
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Recent governance activity OpenAI recorded 16 documented changes in the last 30 days.
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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)

Customer Content that triggers policy flags may be disclosed to third-party sub-processors, expanding the set of entities that access that content beyond OpenAI itself.

Consumer impact (what this means for users)

If OpenAI's models flag your content as violating its policies, samples of that content may be shared with sub-processors to assist OpenAI's review.

How other platforms handle this

Squarespace Medium

we may use, retain or share information with law enforcement or others in circumstances where a person's vital interests require protection, such as in the case of emergencies.

Ancestry Medium

Any such de-identified genetic information and phenotypic information we share with third parties for research purposes is done in accordance with Part 46 (beginning with Section 46.101) of Title 45 of the Code of Federal Regulations.

Zoom Medium

Perplexity may process the following data if AI features are enabled: Customer Content and context

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▸ View Original Clause Language DOCUMENT RECORD
"
For content that OpenAI's models flag as being in violation of OpenAI's policies, OpenAI may share samples of the flagged Customer Content with relevant Sub-processors to assist OpenAI in its review...

— 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-069986
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-069986
Captured: 2026-07-06 23:01:36 UTC
SHA-256: a031cf75d704b4e3…
URL: https://conductatlas.com/platform/openai/openai-sub-processor-list/provision/CA-P-069986/moderation-sharing-limited-to-flagged-content-samples/
Accessed: July 12, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does OpenAI's Moderation sharing limited to flagged content samples clause do?

Customer Content that triggers policy flags may be disclosed to third-party sub-processors, expanding the set of entities that access that content beyond OpenAI itself.

How does this clause affect you?

If OpenAI's models flag your content as violating its policies, samples of that content may be shared with sub-processors to assist OpenAI's review.

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.