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 'at this time' qualifier signals that this human-review requirement is a current practice rather than a permanent policy, leaving open the possibility of future change.
Interpretive note: The phrase 'at this time' is a significant temporal qualifier indicating the practice may not be permanent. This is preserved in all reader-facing fields.
The updated policy discloses that Substack obtains additional information from third parties and sources beyond what it directly collects from you on the platform. This third-party information is combined with platform data to provide what Substack describes as more relevant and safer experiences, and to improve platform analytics. The policy also clarifies that Substack shares account identifiers with child safety industry consortia and receives information from them to detect CSAM. You can review Substack's full privacy policy to understand which third parties may be sources of this information and how your data may be combined with external sources.
View change record →The updated policy discloses that Substack shares account identifiers (email addresses and usernames) with trusted child safety organizations to detect and prevent online child sexual exploitation and abuse. Users now have the right to object to processing of their personal information for personalization purposes on grounds relating to their particular situation, and Substack commits to responding to privacy rights requests within one month. The policy also clarifies that while recipients of direct messages may retain them independently, the platform may restrict your access to messages when other users delete or block you. You can exercise your right to object to personalization processing by contacting privacy@substackinc.com.
View change record →Users subject to content moderation actions can currently expect that no final decision will be reached solely through automated means, as human review is required.
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"At this time, no final content moderation decisions are made without human review of any automated decisions.Excerpt from Substack's Privacy Policy
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The 'at this time' qualifier signals that this human-review requirement is a current practice rather than a permanent policy, leaving open the possibility of future change.
Users subject to content moderation actions can currently expect that no final decision will be reached solely through automated means, as human review is required.
ConductAtlas has identified this type of provision across 210 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Substack.