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

Sub-processor moderation retention limited to review period

High severity High confidence Explicitdocumentlanguage Common · 275 of 352 platforms
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Recent governance activity OpenAI recorded 14 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)

The retention and use of flagged content by sub-processors is double-limited: by time (review period only) and by purpose (assisting OpenAI's review only), constraining how sub-processors can handle that content.

Consumer impact (what this means for users)

Sub-processors that receive samples of your flagged content may only keep those samples during the review period and may only use them to assist OpenAI's review.

How other platforms handle this

Palantir Medium

We collect and keep personal data only as needed or allowed for the purposes set out in this Statement, based on the reason we collected the personal data in the first instance and what is permitted under the laws that apply to the processing.

Faire Medium

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information...

Mistral AI Medium

Mistral AI shall retain the Customer Exportable Data and Assets for a period of thirty (30) days from the earlier between (a) the expiration of the Transitional Period or (b) Customer's notification under Section 2.2.2 (b) of these Additional Terms.

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▸ View Original Clause Language DOCUMENT RECORD
"
the Sub-processor platform only retains samples of content for the period of review, and OpenAI's Sub-processors only process the content to assist OpenAI in its review.

— Excerpt from OpenAI's OpenAI Sub-Processor List

Applicable regulations

CCPA/CPRA
California, USA
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
UK GDPR
United Kingdom

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-069988
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-069988
Captured: 2026-07-06 23:01:36 UTC
SHA-256: a031cf75d704b4e3…
URL: https://conductatlas.com/platform/openai/openai-sub-processor-list/provision/CA-P-069988/sub-processor-moderation-retention-limited-to-review-period/
Accessed: July 13, 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 Sub-processor moderation retention limited to review period clause do?

The retention and use of flagged content by sub-processors is double-limited: by time (review period only) and by purpose (assisting OpenAI's review only), constraining how sub-processors can handle that content.

How does this clause affect you?

Sub-processors that receive samples of your flagged content may only keep those samples during the review period and may only use them to assist OpenAI's review.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 275 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.