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

Standard Contractual Clauses govern affiliate data transfers

High severity High confidence Explicitdocumentlanguage Common · 272 of 352 platforms

Key Facts

What does OpenAI use as the valid transfer mechanism for data transfers among its affiliates?
OpenAI uses Standard Contractual Clauses as the valid transfer mechanism for data transfers among its affiliates.
Get alerted the next time OpenAI changes these terms. Follow OpenAI →
Share 𝕏 Share in Share 🔒 PDF
Recent governance activity OpenAI recorded 23 documented changes in the last 30 days.
Follow OpenAI →
Monitor governance changes for OpenAI Monitor emails you the same day this changes. The archive stays free.
Follow OpenAI →

Get the weekly research letter

Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean. No account.

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)

Standard Contractual Clauses are the stated legal basis for intra-affiliate data transfers, which determines the framework governing data protection obligations when data moves between OpenAI's related entities.

Consumer impact (what this means for users)

Data transferred between OpenAI's affiliate entities is governed by Standard Contractual Clauses as the stated legal transfer mechanism.

How other platforms handle this

Perplexity AI Medium

You may also request a copy of any Standard Contractual Clauses we use for the transfer of your data outside of the EEA or United Kingdom...

Glassdoor Medium

Glassdoor complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.

ZipRecruiter Medium

The Federal Trade Commission has jurisdiction over ZipRecruiter's compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF.

See all platforms with this clause type →

Monitoring

OpenAI has changed this document before.

Receive same-day alerts, structured change summaries, and monitoring for up to 20 platforms.

Follow OpenAI → Or create a free account →
▸ View Original Clause Language DOCUMENT RECORD
"
We use the Standard Contractual Clauses as a valid transfer mechanism among affiliates.

Excerpt from OpenAI's Sub-Processor List

Applicable regulations

FAA
United States Federal

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-069998
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-069998
Captured: 2026-07-06 23:01:36 UTC
SHA-256: a031cf75d704b4e3…
URL: https://conductatlas.com/platform/openai/openai-sub-processor-list/provision/CA-P-069998/standard-contractual-clauses-govern-affiliate-data-transfers/
Accessed: July 25, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

Other risks in this policy

Governance intelligence across arbitration, AI governance, data rights, indemnification, and retention

Provision-level monitoring, governance timelines, and regulatory mapping built from archived source documents and historical version tracking.

Frequently Asked Questions

What does OpenAI's Standard Contractual Clauses govern affiliate data transfers clause do?

Standard Contractual Clauses are the stated legal basis for intra-affiliate data transfers, which determines the framework governing data protection obligations when data moves between OpenAI's related entities.

How does this clause affect you?

Data transferred between OpenAI's affiliate entities is governed by Standard Contractual Clauses as the stated legal transfer mechanism.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 272 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.