Provision record
OpenAI · OpenAI Usage Policies · View original document ↗

Prohibition on Real-Time Remote Biometric Identification in Public Spaces

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Document Record

What it is

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

The policy prohibits using OpenAI services for real-time remote biometric identification in public spaces, building facial recognition databases without data subject consent, and evaluating or classifying individuals based on biometric data, social behavior, or personal traits including social scoring and profiling.

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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

This provision establishes a categorical prohibition on a class of AI applications that regulatory frameworks including the EU AI Act designate as prohibited practices, creating a policy-level alignment with regulatory requirements that API customers and developers must independently satisfy under applicable law.

Consumer impact (what this means for users)

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

This provision establishes that OpenAI services may not be used to build systems that identify individuals in public spaces via biometrics in real time, create facial recognition databases, or score or profile individuals based on personal traits or social behavior without their authorization.

Cross-platform context

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▸ View Original Clause Language DOCUMENT RECORD
"
Respect privacy. People are entitled to privacy. So, we don't allow attempts to compromise the privacy of others, including to aggregate, monitor, profile, or distribute individuals' private or sensitive information without their authorization. And, you may never use our services for: facial recognition databases without data subject consent real-time remote biometric identification in public spaces use of someone's likeness, including their photorealistic image or voice, without their consent in ways that could confuse authenticity evaluation or classification of individuals based on their social behavior, personal traits, or biometric data (including social scoring, profiling, or inferring sensitive attributes)

Excerpt from OpenAI's Usage Policies

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

(1) REGULATORY LANDSCAPE: This provision directly engages the EU AI Act's list of prohibited AI practices, which includes real-time remote biometric identification in publicly accessible spaces and AI systems used for social scoring by public …

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →
  • State Attorney General
    State AGs in California, New York, Texas, and other states can investigate violations of state consumer protection and privacy laws, including CCPA (California), SHIELD Act (New York), and equivalents.
    Who can file: Residents of states with comprehensive privacy laws — primarily California, Virginia, Colorado, Connecticut, and Utah
    What you need: Evidence of the violation, explanation of how your state rights were affected, and your account or contact information with the company
    What to expect: Outcomes vary by state. May result in investigation, enforcement action, or requirement for the company to change practices. No direct individual compensation in most cases.

    Search "[your state] attorney general consumer complaint" to find your state's direct complaint form

Provision details

Document information
Document
OpenAI Usage Policies
Entity
OpenAI
Date stated by the document
Oct. 29, 2025
As printed in OpenAI’s text (version CA-V-005278), not a ConductAtlas date.
Tracking information
First captured by ConductAtlas
May 11, 2026
Text quoted from version
CA-V-005278, captured July 26, 2026
Record ID
CA-P-013634
Document ID
CA-D-000753
Evidence Provenance
Source URL
Wayback Machine
Extracted-text SHA-256 (version CA-V-005278)
c0233b83a5bc2cc40b8fcd5df1b4dbe3dd6524a971181e86cd479ebdede4f622
Analysis generated
July 9, 2026 03:38 UTC
Methodology
Evidence
✓ Excerpt found in version CA-V-005278, captured July 26, 2026 (checked Oct. 5, 2026)
Citation Record
Entity: OpenAI
Document: OpenAI Usage Policies
Record ID: CA-P-013634
Version: CA-V-005278
Captured: 2026-07-26 00:02:38 UTC
SHA-256: c0233b83a5bc2cc4…
URL: https://conductatlas.com/platform/openai/openai-usage-policies/provision/CA-P-013634/prohibition-on-real-time-remote-biometric-identification-in-public-spaces/
Accessed: Nov. 10, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Categories

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Frequently Asked Questions

What does OpenAI's Prohibition on Real-Time Remote Biometric Identification in Public Spaces clause do?

This provision establishes a categorical prohibition on a class of AI applications that regulatory frameworks including the EU AI Act designate as prohibited practices, creating a policy-level alignment with regulatory requirements that API customers and developers must independently satisfy under applicable law.

How does this clause affect you?

This provision establishes that OpenAI services may not be used to build systems that identify individuals in public spaces via biometrics in real time, create facial recognition databases, or score or profile individuals based on personal traits or social behavior without their authorization.

Is ConductAtlas affiliated with OpenAI?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by OpenAI.