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The policy discloses that Thomson Reuters collects and processes the content of user queries submitted to its Services, explicitly including artificial intelligence prompts, as a category of personal information.
This analysis describes what Thomson Reuters'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
This provision establishes that AI prompt content constitutes a collected personal data category subject to the full range of uses described in the statement, including service improvement, product development, annotating and tagging content, and sharing with third-party business partners. Organizations using Thomson Reuters AI products such as CoCounsel should evaluate whether client-confidential or privileged content submitted as AI prompts is subject to these data handling practices.
Under this clause, content submitted as AI prompts through Thomson Reuters Services is collected as user content and may be used for service operation, improvement, product development, metadata annotation, and sharing with third-party business partners as described in the statement.
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"User contributions & user content Personal information in content and communications uploaded, sent, shared, or inputted through our Services or via our networks and infrastructure, including feedback you provide to us and the content of communications between you and us or sent via our network and Services — including the content of your queries on our Services, such as artificial intelligence promptsExcerpt from Thomson Reuters's Privacy
1) REGULATORY LANDSCAPE: AI prompt content may include personal data subject to GDPR, CCPA/CPRA, and other applicable data protection frameworks. For legal professionals, prompts may contain attorney-client privileged or work-product-protected information, engaging professional responsibility rules across jurisdictions. The EU AI Act may impose additional transparency and data governance obligations on AI systems that process personal data, though the specific applicability to CoCounsel and related products depends on their classification under that framework. 2) GOVERNANCE EXPOSURE: High for law firm and corporate legal department users. Legal professionals submitting client information or case strategy as AI prompts may create confidentiality and privilege risks if prompt content is retained and used for purposes beyond immediate query fulfillment, including product development or third-party sharing. The statement does not carve out privileged or confidential professional content from its general data use provisions. 3) JURISDICTION FLAGS: EU and UK users are subject to GDPR and UK GDPR obligations regarding the lawful basis for processing AI prompt content and any onward transfer of that content. California users retain CCPA/CPRA rights over personal information in AI prompts. Legal professionals in all jurisdictions should evaluate applicable bar rules and professional responsibility guidance on sharing client information with AI vendors. 4) CONTRACT AND VENDOR IMPLICATIONS: Law firm and corporate legal department procurement teams should assess whether Thomson Reuters' data processing agreements for CoCounsel and related AI products contain specific provisions governing prompt content retention, use for training or product development, and third-party sharing. If the general privacy statement governs absent a specific DPA carve-out, AI prompt content may be subject to broader use than professional users anticipate. 5) COMPLIANCE CONSIDERATIONS: Legal and compliance teams should review whether their organization's AI usage policies address the submission of client-confidential or privileged content to Thomson Reuters AI tools, and whether existing data processing agreements with Thomson Reuters restrict prompt content use to service delivery only. Model governance frameworks should document the data retention and use practices applicable to AI prompt content across all Thomson Reuters AI products in use.
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This provision establishes that AI prompt content constitutes a collected personal data category subject to the full range of uses described in the statement, including service improvement, product development, annotating and tagging content, and sharing with third-party business partners. Organizations using Thomson Reuters AI products such as CoCounsel should evaluate whether client-confidential or privileged content submitted as AI prompts is …
Under this clause, content submitted as AI prompts through Thomson Reuters Services is collected as user content and may be used for service operation, improvement, product development, metadata annotation, and sharing with third-party business partners as described in the statement.
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