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

Sub-processor moderation retention limited to review period

High confidence Common · 268 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

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)

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

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

Target

At the end of the retention period, personal information will be deleted, destroyed, or deidentified.

Hilton

We will promptly destroy personal information at the end of the retention period, as described above. When we destroy personal information, we do so in a way that prevents that information from being restored or reconstructed.

StockX

We will retain your Personal Information for as long as we need it to provide you with access to our Services or to fulfill the purposes for which it was collected...

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
Sharing with the Sub-processor platform only occurs when content is flagged, 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 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-069988
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. 6, 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-069988
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-069988/sub-processor-moderation-retention-limited-to-review-period/
Accessed: Nov. 3, 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 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 268 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.