OpenAI · Usage Policies · View original document ↗

Unlawful Surveillance and Tracking Prohibition

Medium severity Medium confidence Inferredfromcontext Unique · 0 of 343 platforms
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Document Record

What it is

The policy prohibits using OpenAI services to build tools that enable stalkerware, mass surveillance of individuals without their knowledge or consent, or monitoring systems that violate civil rights.

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)

This prohibition addresses the use of AI to enable invasive personal tracking, including applications designed to covertly monitor individuals' communications, location, or activity without consent.

Interpretive note: Verbatim text could not be extracted from the binary PDF. The exact scope of prohibited surveillance versus permissible monitoring use cases is not fully defined in available document text, creating interpretive ambiguity for edge cases.

Clause Stability Stable

0
Changes
3
Months Monitored
May 12, 2026
First Seen
May 22, 2026
Last Seen
This clause type exists across 381 other provisions on other platforms.

Consumer impact (what this means for users)

Developers who use the OpenAI API to build applications that covertly monitor individuals' communications, location data, or online activity without their knowledge are in violation of this policy and subject to API access termination.

How other platforms handle this

Grubhub Medium

When you use the Platform, we collect internet usage information about you, such as information about your browsing behavior, search history on the Platform, and information about your interactions with the Platform and our advertisements, including advertisement impressions and whether you clicked ...

LangChain Medium

We use cookies, web beacons, pixel tags, and other tracking technologies to collect information about your use of our services, including pages visited, links clicked, browser type, IP address, and device identifiers. We may use this information for analytics, advertising, and to improve our service...

Amplitude Medium

We offer a Session Replay product that allows our customers to record and replay user sessions on their websites and applications. Session Replay may capture information such as mouse movements, clicks, scrolls, and form inputs. Amplitude customers are responsible for ensuring they have the necessar...

See all platforms with this clause type →

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ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

1. REGULATORY LANDSCAPE: This provision intersects with the Electronic Communications Privacy Act (ECPA), state wiretapping statutes, and GDPR Articles 5, 6, and 9 regarding lawful basis for processing personal data including location data and communications content. The FTC has previously brought enforcement actions against stalkerware developers under Section 5 of the FTC Act. The EU AI Act classifies certain real-time biometric identification and mass surveillance systems as prohibited AI practices. 2. GOVERNANCE EXPOSURE: High for operators in workforce monitoring, law enforcement technology, parental control, or relationship tracking sectors. The boundary between permissible monitoring (such as consented parental controls) and prohibited surveillance tools may require case-by-case legal assessment and is not fully defined in the available document text. 3. JURISDICTION FLAGS: EU operators face the EU AI Act's prohibition on certain mass surveillance AI systems and GDPR restrictions on processing location and communications data without a lawful basis. Illinois BIPA, California CCPA, and New York SHIELD Act create additional state-level exposure for operators processing biometric or personal identifiers in surveillance contexts. The FTC has jurisdiction over stalkerware operators in the US. 4. CONTRACT AND VENDOR IMPLICATIONS: Operators in workforce analytics, security, or parental monitoring sectors should seek written guidance from OpenAI on the scope of permissible use cases. Contracts should include representations about the lawful basis for any monitoring use case built on the API. 5. COMPLIANCE CONSIDERATIONS: Legal teams should assess whether existing monitoring products built on the OpenAI API fall within permissible bounds. Privacy impact assessments should be conducted for any application involving individual tracking or communications monitoring. Consent mechanisms should be reviewed to ensure they meet applicable legal standards.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC has enforcement authority over stalkerware and covert surveillance software under Section 5 of the FTC Act and has brought prior enforcement actions in this category
    File a complaint →
  • State AG
    State attorneys general have jurisdiction over violations of state wiretapping, electronic surveillance, and consumer protection statutes applicable to stalkerware and covert monitoring tools
    File a complaint →

Applicable regulations

EU AI Act
European Union
BIPA
Illinois, USA
CCPA/CPRA
California, USA
Colorado AI Act
US-CO
CAN-SPAM
United States Federal
ePrivacy Directive
European Union
EU AI Act - High Risk Provisions
EU
FTC Act Section 5
United States Federal
GDPR
European Union
UK GDPR
United Kingdom

Provision details

Document information
Document
Usage Policies
Entity
OpenAI
Document last updated
March 5, 2026
Tracking information
First tracked
March 10, 2026
Last verified
May 12, 2026
Record ID
CA-P-011461
Document ID
CA-D-00005
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
d69a24617758e5b44e4be8eedeceb598a26dc4e280f2ab1469a45b64203e7403
Analysis generated
March 10, 2026 03:28 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: OpenAI
Document: Usage Policies
Record ID: CA-P-011461
Captured: 2026-03-10 03:28:59 UTC
SHA-256: d69a24617758e5b4…
URL: https://conductatlas.com/platform/openai/usage-policies/unlawful-surveillance-and-tracking-prohibition/
Accessed: July 1, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

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Frequently Asked Questions

What does OpenAI's Unlawful Surveillance and Tracking Prohibition clause do?

This prohibition addresses the use of AI to enable invasive personal tracking, including applications designed to covertly monitor individuals' communications, location, or activity without consent.

How does this clause affect you?

Developers who use the OpenAI API to build applications that covertly monitor individuals' communications, location data, or online activity without their knowledge are in violation of this policy and subject to API access termination.

Is ConductAtlas affiliated with OpenAI?

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