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

Moderation sharing limited to flagged content samples

High confidence Common · 281 of 343 platforms
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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)

Generated by a model from the captured document; not read by a person

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)

Generated by a model from the captured document; not read by a person

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

Kling AI

We may share your personal data with a third party for purposes other than processing on our behalf. We will obtain your consent to such disclosure as required by applicable laws.

Together AI

We may share your Personal Data with Service Providers, Third-Party Vendors, Consultants, and other Business Partners in order to provide Services on our behalf...

Harvey AI

These third parties have limited access to your information, may use your information only to perform agreed tasks, and are prohibited from disclosing or using your information for other purposes.

See all platforms with this clause type →
▸ 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 Sub-Processor List

Provision details

Document information
Document
OpenAI Sub-Processor List
Entity
OpenAI
Date stated by the document
Oct. 14, 2026
As printed in OpenAI’s text (version CA-V-007534), not a ConductAtlas date.
Tracking information
First captured by ConductAtlas
July 6, 2026
Text quoted from version
CA-V-005774, captured Aug. 14, 2026
Record ID
CA-P-069986
Document ID
CA-D-000928
Evidence Provenance
Source URL
Wayback Machine
Extracted-text SHA-256 (version CA-V-005774)
2007f77524532432cd3b5bebbd4a66ca73131eca6a09f65aa148e7ccf545cb78
Analysis generated
July 6, 2026 23:01 UTC
Methodology
Evidence
✓ Excerpt found in version CA-V-005774, captured Aug. 14, 2026 (checked Oct. 5, 2026)
Not the current version. The document's current version is CA-V-007534, captured Oct. 15, 2026; this clause has not been re-checked against it.
Citation Record
Entity: OpenAI
Document: OpenAI Sub-Processor List
Record ID: CA-P-069986
Version: CA-V-005774
Captured: 2026-08-14 00:07:28 UTC
SHA-256: 2007f77524532432…
URL: https://conductatlas.com/platform/openai/openai-sub-processor-list/provision/CA-P-069986/moderation-sharing-limited-to-flagged-content-samples/
Accessed: Oct. 24, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Categories

Other risks in this policy

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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 281 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.