Provision record
Upwork · Upwork Privacy Policy · View original document ↗

User Content License for Feedback and Composite Information

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Document Record

What it is

The agreement establishes that users consent to Upwork publishing individual and composite feedback about them, including job success scores and user ratings, to other users and the public, and that Upwork reserves the right to remove feedback that violates its terms or is inconsistent with its business interests.

This analysis describes what Upwork'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 provision authorizes Upwork to aggregate and publish reputational data about individual users, including composite scores derived from multiple user interactions, and reserves Upwork's discretion to remove feedback based on its own business interests assessment, which is an operational factor affecting how freelancer and client reputations are managed on the platform.

Recent Activity

This document changed recently

Medium Jul 1, 2026

The updated terms establish a new beta feature allowing invited users to connect third-party AI agents to their Upwork accounts. Agents can read information and draft communications (proposals, job posts, messages) without per-action confirmation, but cannot autonomously move money or finalize contracts; those actions require the user to authenticate and confirm on Upwork directly. Users are responsible for all agent actions and must ensure agent-generated content carries mandatory disclosure labels; submitting proposals through agents consumes Connects and incurs fees regardless of whether the user approves the draft-confirm action. You can revoke agent access by visiting the App Authorization page, and these beta terms apply only until you accept replacement terms.

View change record →
High May 1, 2026

Upwork's privacy policy previously disclosed that it complied with the U.S. Data Privacy Framework and certified adherence to its Principles regarding how it processes personal data from EU, UK, and Swiss residents. The updated policy removes nearly all of this language, including the explicit commitment to Data Privacy Framework Principles and the statement that those Principles would govern in case of conflict with other policy terms. Users in the EU, UK, and Switzerland no longer have a clear, policy-level statement of the legal framework protecting their data when transferred to the U.S., which may reduce transparency about data protection safeguards. You may contact Upwork to request copies of the data transfer mechanism documents it uses.

View change record →
Medium Apr 19, 2026

The updated policy now explicitly states that Upwork complies with the U.S. Data Privacy Framework and has certified to the U.S. Department of Commerce that it adheres to DPF principles when processing personal data from EU, UK, and Swiss residents. The policy establishes that if any conflict exists between Upwork's privacy policy and DPF principles, the DPF principles will govern. This creates an explicit legal hierarchy for data protection standards applicable to residents of those jurisdictions. Users from affected regions can visit https://www.dataprivacyframework.gov/ to view Upwork's certification and learn more about the DPF program.

View change record →

Clause Stability Stable

0
Changes
4
Months Monitored
Jul 9, 2026
First Seen
Jul 9, 2026
Last Seen

Consumer impact (what this means for users)

Under this clause, users grant Upwork authorization to publish composite feedback, job success scores, and reputational data about them to other users, and Upwork retains discretion to remove feedback it determines negatively affects its marketplace, which may affect a freelancer's or client's profile visibility and profile score.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Dispute a Fee
    If you identify an error or inaccuracy in your feedback results or composite information on Upwork, notify Upwork through the support portal and provide details of the specific inaccuracy as required by Section 2.3 of the User Agreement.

Cross-platform context

See how other platforms handle User Content License for Feedback and Composite Information and similar clauses.

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▸ View Original Clause Language DOCUMENT RECORD
"
You acknowledge and agree that Users publish and request Upwork to publish on their behalf information on the Site such as feedback, composite feedback, or geographical location. Such information is based on data that Freelancers or Clients voluntarily submit to Upwork and does not constitute an introduction, endorsement, or recommendation by Upwork. You acknowledge and agree that User feedback benefits the marketplace and its Users, and you specifically request and agree that Upwork may make available to other Users individual and composite feedback about Users, including you.

Excerpt from Upwork's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

(1) REGULATORY LANDSCAPE: Publication of reputational and composite scoring data about individuals engages GDPR provisions on profiling and automated decision-making for EU users, particularly where composite scores may influence hiring or contracting decisions; CCPA and …

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 →

Provision details

Document information
Document
Upwork Privacy Policy
Entity
Upwork
Document last updated
May 5, 2026
Tracking information
First tracked
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-014805
Document ID
CA-D-00142
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
a8317ef805233afd22c54b506ede241c26f34e99dfe8e9b9bde9646a3a54833d
Analysis generated
July 9, 2026 06:28 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Upwork
Document: Upwork Privacy Policy
Record ID: CA-P-014805
Captured: 2026-07-09 06:28:32 UTC
SHA-256: a8317ef805233afd…
URL: https://conductatlas.com/platform/upwork/upwork-privacy-policy/provision/CA-P-014805/user-content-license-for-feedback-and-composite-information/
Accessed: Sept. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Upwork's User Content License for Feedback and Composite Information clause do?

This provision authorizes Upwork to aggregate and publish reputational data about individual users, including composite scores derived from multiple user interactions, and reserves Upwork's discretion to remove feedback based on its own business interests assessment, which is an operational factor affecting how freelancer and client reputations are managed on the platform.

How does this clause affect you?

Under this clause, users grant Upwork authorization to publish composite feedback, job success scores, and reputational data about them to other users, and Upwork retains discretion to remove feedback it determines negatively affects its marketplace, which may affect a freelancer's or client's profile visibility and profile score.

Is ConductAtlas affiliated with Upwork?

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