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

Private GPT moderation requires customer initiation

Medium severity High confidence Explicitdocumentlanguage Common · 144 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)

OpenAI does not proactively moderate private GPTs; moderation is contingent on customer action, meaning problematic private GPTs may go unreviewed without a customer-initiated report.

Consumer impact (what this means for users)

If a GPT is kept private to your individual account or workspace, OpenAI will not moderate it unless your organization initiates the process.

How other platforms handle this

Tinder Medium

We use a combination of automated tools and human reviewers to enforce our content rules. This includes technology that proactively detects and removes certain types of prohibited material.

Glassdoor Medium

We moderate Content using proprietary technology that analyzes multiple attributes of the content for compliance with our Guidelines. If the Content does not pass technological review, it is rejected and not made visible on our services.

Hinge Medium

We use a combination of automated tools and human reviewers to enforce our content rules. This includes technology that proactively detects and removes certain types of prohibited material.

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▸ View Original Clause Language DOCUMENT RECORD
"
For GPTs that are kept private to an individual or workspace, moderation activities must be initiated by the Customer, for instance if a user within the Customer's workspace reports the GPT...

— Excerpt from OpenAI's OpenAI Sub-Processor List

Applicable regulations

California AB 2013 AI Training Data Transparency
US-CA
DMCA
United States Federal
DSA
European Union

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-069990
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-069990
Captured: 2026-07-06 23:01:36 UTC
SHA-256: a031cf75d704b4e3…
URL: https://conductatlas.com/platform/openai/openai-sub-processor-list/provision/CA-P-069990/private-gpt-moderation-requires-customer-initiation/
Accessed: July 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does OpenAI's Private GPT moderation requires customer initiation clause do?

OpenAI does not proactively moderate private GPTs; moderation is contingent on customer action, meaning problematic private GPTs may go unreviewed without a customer-initiated report.

How does this clause affect you?

If a GPT is kept private to your individual account or workspace, OpenAI will not moderate it unless your organization initiates the process.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 144 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.