Substack employees can read your private messages for a range of reasons including enforcing rules, security, support, or simply as needed to operate the service, and automated systems also scan message content.
This analysis describes what Substack'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
The 'as otherwise necessary to provide our services' language is a broad catch-all that extends staff access to direct message contents beyond specific safety or legal scenarios, which may not align with user expectations of private messaging.
Interpretive note: The scope of 'as otherwise necessary to provide our services' is operationally ambiguous and may be interpreted more or less broadly depending on enforcement context or applicable law.
Substack now discloses that it shares account identifiers, such as email addresses and usernames, with trusted industry child safety organizations to detect and prevent online child sexual exploitation and abuse. The policy also establishes that Substack will respond to privacy rights requests within one month, or up to three months for complex requests, providing more certainty about response timelines. Additionally, the policy clarifies that direct message recipients may retain messages even if you request deletion or delete your account, which is now explicitly stated rather than implied.
View change record →The updated policy no longer commits to responding to privacy rights requests within one month or within three months for complex requests. This removes a procedural timeline that previously bound Substack's response obligations. Additionally, the explicit disclosure that Substack shares account identifiers with child safety consortia to detect online child sexual exploitation has been removed from the policy, though the practice itself is not stated to have ended. The direct message retention language is now framed more directly: recipients may retain messages even if you request deletion or close your account.
View change record →Removal of explicit disclosure about staff access to direct message contents may obscure internal monitoring practices from users.
View full change record →This provision means your Substack direct messages are subject to human review by company staff and automated scanning, across a range of operational purposes, which users treating the platform as a private messaging service should carefully consider.
How other platforms handle this
Your organization may allow you to access and export your data in order to back it up or transfer it to a service outside of Google.
It also means we are unable to provide any information about messages in your Revolut Messenger even if you ask us for it.
Access information about you consistent with legal requirements. In addition, you may have the right in some cases to receive or have your electronic information transferred to another party.
"While we maintain strict internal access controls on direct messaging content, keep in mind that Substack personnel may access the contents of direct messages to enforce our Terms of Use, ensure the security of our platform, to provide user support, or as otherwise necessary to provide our services. We may also use automated means to ensure the safety of direct messaging content, including scanning for spam, malicious content, and child abuse material.Excerpt from Substack's Privacy Policy
REGULATORY LANDSCAPE: This provision implicates GDPR Article 6 legal basis requirements for processing personal data (specifically message content) and Article 5 data minimization principles.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
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The 'as otherwise necessary to provide our services' language is a broad catch-all that extends staff access to direct message contents beyond specific safety or legal scenarios, which may not align with user expectations of private messaging.
This provision means your Substack direct messages are subject to human review by company staff and automated scanning, across a range of operational purposes, which users treating the platform as a private messaging service should carefully consider.
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Substack.