OpenAI
AI API · openai.com · last read 2026-11-09
At a glance
- Is OpenAI GDPR compliant?
- No tool is GDPR compliant on its own: compliance depends on what you process with it and how. What follows is what OpenAI itself publishes, each answer linked to its source and the date we read it.
- Does OpenAI have a data processing agreement (DPA)?
- Yes. OpenAI publishes a data processing agreement at openai.com. It describes how a new subprocessor is announced but states no notice period. It promises breach notification "without undue delay", with no number of hours. Source and date
- Which version of the OpenAI DPA is current?
- On 2026-11-09, OpenAI's DPA at openai.com printed “Updated: December 1, 2025 Effective: January 1, 2026”. Source and date
- Does OpenAI have a SOC 2 report?
- OpenAI says a SOC 2 Type 2 report is available on request. In OpenAI's words: “Customers with active trust.openai.com accounts can access the latest report under "Compliance" > "SOC 2 Type 2."” We read this on 2026-10-05. Source and date
- Is OpenAI ISO 27001 certified?
- OpenAI states ISO/IEC 27001 certification (2022 edition, as OpenAI names it), and says the certificate or audit report is available on request. We read this on 2026-10-05. Source and date
- Where is OpenAI's trust center?
- OpenAI publishes a page it calls “Trust Portal” at trust.openai.com. Some of its documents sit behind a request or sign-in: the page says “Get access”. The page mentions SOC 2, ISO 27001, a penetration test, subprocessors, security questionnaires and a DPA. We read it on 2026-11-03. Source and date
- Does OpenAI use your data to train AI models?
- For consumer plans (ChatGPT, Sora, and Operator): content may be used to train models; users can opt out via privacy portal or settings; Temporary Chat not used for training. For business plans (ChatGPT Business, Enterprise, Healthcare, Edu, Teachers): not used for training by default unless the customer explicitly opts in to share data (e.g. feedback). For the API (API Platform): not used for training by default (data after March 1, 2023) unless the customer explicitly opts in. Source and date
- What is OpenAI's data retention for AI prompts and outputs?
- For business plans (ChatGPT Business): workspace admins set retention; deleted or unsaved conversations removed within 30 days. For business plans (ChatGPT Enterprise, Edu, Healthcare): workspace admins set retention; deleted conversations removed within 30 days. For the API (API Platform): API inputs and outputs retained up to 30 days, then removed. For the API (OpenAI API): Abuse monitoring logs (may include prompts and responses) retained up to 30 days by default, longer if required by law or to prevent harm. Source and date
- Does OpenAI offer zero data retention?
- For the API (API Platform): zero data retention on request for eligible endpoints with a qualifying use-case. For the API (OpenAI API): Zero Data Retention or Modified Abuse Monitoring for eligible customers, subject to prior approval by OpenAI. Source and date
- Can OpenAI process AI data in the EU?
- For the API (OpenAI API): Data residency with regional inference in supported regions (incl. Europe EEA + Switzerland); eligibility via sales, requires approved abuse monitoring controls for non-US regions. Source and date
- How does OpenAI transfer personal data out of the EU?
- OpenAI's agreement relies on the EU standard contractual clauses and the UK transfer addendum. We found no entry for OpenAI on the official Data Privacy Framework List. Source and date
- Does OpenAI offer EU data residency?
- An EU location exists but requires a paid plan or add-on. Plan it needs: Eligible customers, new Projects only. Source and date
- Who are OpenAI's subprocessors?
- OpenAI lists 17 third-party subprocessors; 16 of them name at least one processing country outside the EEA. We last read the list on 2026-10-19. We have recorded 1 change to it, the latest on 2026-10-19. Source and date
- How do you report a security vulnerability to OpenAI?
- OpenAI publishes a security.txt at openai.com naming https://bugcrowd.com/openai or [email protected]. The file falls short of RFC 9116: no Expires field. Source and date
The same questions for any vendor, and the rule behind each: the vendor due diligence checklist.
Identity
| Legal entity | OpenAI OpCo, LLC |
|---|---|
| HQ | US |
| Parent company | — |
| Ultimate ownership | US |
| EU contracting entity | OpenAI Ireland Ltd. |
| LEI | 984500C7AD3A48B9FP18 |
| US CLOUD Act reach | Contracting entity incorporated in the US |
| Source | cdn.openai.com · 2026-10-08 |
Legal entity from the vendor's own terms. LEI, registered country and parent company from the Global LEI Index (GLEIF); ownership is left empty where GLEIF names no parent. The CLOUD Act row is arithmetic over those countries, not an assessment of risk.
OpenAI data residency
| Region | EU data location | Minimum plan | Source | Observed |
|---|---|---|---|---|
| EU | Paid upgrade | Eligible customers, new Projects only | developers.openai.com | 2026-09-18 |
EU: Reviewed 2026-09-18: the first citation for this row was help.openai.com, which is a stub reading 'This content has moved' and stating only that eligible customers may opt to process data in Europe. It did not support the uplift, the new-Projects limit or the sales gate, so the row is re-cited to the page that does. That page states: 'Contact our sales team to see if you are eligible for using data residency controls. Data residency endpoints are charged a 10% uplift for models released on or after March 5, 2026, that are eligible for data residency.' A region may be set only for NEW projects. Residency does not cover system data - account data, metadata, usage data, billing and support - which may be processed outside the selected region.
The same question for every vendor: where SaaS vendors store EU data.
OpenAI's subprocessor list names AWS, Microsoft, Google and Oracle for hosting or infrastructure. Which SaaS vendors run on which cloud, and the sovereign offerings of each: sovereign clouds.
Subprocessor chain
17 third parties · 5 of the vendor's own group companies · 16 with a country outside the EEA · all read 2026-10-19
| Subprocessor | Country | Purpose |
|---|---|---|
| Accenture International Limited | US, CA, PH | Customer support; moderation of content |
| Amazon Web Services, Inc. | US | Cloud infrastructure |
| Cerebras | US, CA | Cloud infrastructure |
| Cinder Technologies, Inc. | US | Platform for content moderation; platform for moderation of GPTs |
| Cloudflare, Ltd. | — | Content delivery network provider |
| Cloudflare, Ltd. | US | Web Hosting |
| CoreWeave, Inc. | NO, ES, SE, GB, US | Cloud infrastructure |
| Fivetran, Inc. | US | ETL provider |
| Google Cloud Platform | FI, JP, NL, NO, SG, GB, US | Cloud infrastructure |
| Merge API, Inc. | AU, CA, FR, IN, IE, JP, SG, KR, SE, GB, US | Infrastructure management |
| Microsoft Corporation | AU, BE, BR, CA, DK, FR, DE, IN, ID, IE, IT, JP, MY, MX, NL, NZ, NO, PL, SG, ZA, KR, ES, SE, CH, AE, GB, US | Cloud infrastructure |
| Oracle Cloud Infrastructure | BR, JP, MY, NL, GB, US | Cloud infrastructure |
| Pylon Labs | US | Customer support (at election of customer; premium support only) |
| Salesforce | AU, BR, CA, FR, DE, IN, ID, IE, IT, JP, SG, ZA, KR, SE, CH, NL, AE, GB, US | Customer support |
| Snowflake, Inc. | US | Data warehousing |
| TaskUs, LLC | PH | Customer support; moderation of content; moderation of GPTs |
| WorkOS, Inc. | US | Cross-domain identity management |
OpenAI's own group companies listed as subprocessors (5)
| Company | Country | Purpose |
|---|---|---|
| OAI International, Inc. | US | Technical and operational support for the Services |
| OpenAI Ireland Ltd. | IE | Technical and operational support for the Services |
| OpenAI Japan Ltd. | JP | Technical and operational support for the Services |
| OpenAI UK Ltd. | GB | Technical and operational support for the Services |
| OpenAI, OpCo, LLC | US | Technical and operational support for the Services |
The count outside the EEA is arithmetic over the country column, not a judgement about lawfulness. A transfer outside the EEA can be perfectly lawful; whether this one is depends on your use, not on the vendor.
Every subprocessor in the registry, and which vendors name it: subprocessors.
Processing terms
From the vendor's data processing agreement · read 2026-10-09 · openai.com
| Term | What the agreement says |
|---|---|
| Transfer mechanism | SCC module 2 |
| Transfer mechanism | SCC module 3 |
| Transfer mechanism | UK Addendum |
| Transfer mechanism | other |
| Notice of new subprocessors | Notice of Sub-Processor List changes via blog post, in-Services notification or other reasonable means, or by email if Customer subscribes; no advance notice period stated |
| Notice of new subprocessors | Prior notice under SCC Clause 9 Option 2 (general written authorization); minimum period as set forth in Section 2.9 of the DPA |
| If you object to one | Object within 30 days of notice (per Sub-Processor List instructions or [email protected]); OpenAI offers commercially reasonable alternatives; if unresolved within 30 days, either party may terminate the affected Services, with a refund of applicable pre-paid fees |
| Obligations passed to subprocessors | Contractual arrangements with each Sub-Processor imposing obligations comparable to those on OpenAI under the DPA; OpenAI remains liable for Sub-Processors |
| Breach notification | without undue delay |
| Deletion when the service ends | After expiry or termination, return or delete Customer Data and existing copies at Customer's instruction, unless retention is required by law, in which case the data is isolated and protected from further processing |
| Getting your data back | After expiry or termination, Customer Data is returned at Customer's instruction (as an alternative to deletion) |
| Requests from data subjects | informs Customer of requests received, won't respond without Customer's prior written authorization, may redirect requests to Customer; assists via appropriate technical and organizational measures |
| Audit | On reasonable written request, no more than once per year: privacy and security policies and compliance information; audits or inspections by or on behalf of Customer at Customer's sole expense, subject to a confidentiality agreement, minimally disruptive, no more than once per year; OpenAI may instead provide a summary of Audit Reports where permitted |
| Processing on your instructions | only in accordance with Customer's documented instructions (DPA, Agreement, Order Form, in-Service configuration tools), unless required by law, with prior notice to Customer unless legally prohibited |
| Confidentiality of staff | authorized persons committed to confidentiality or under an appropriate statutory obligation of confidentiality |
| Security measures | reasonable and appropriate organizational and technical security measures, as set forth in the Agreement |
Terms as the agreement states them. Where it is silent on a term, there is no row; that is not a statement that the vendor does not offer it.
Which version applies
On 2026-11-09, the agreement printed: Updated: December 1, 2025 Effective: January 1, 2026
at openai.com
In effect from 2026-01-01 · Last updated 2025-12-01
This version is in our copies from 2026-10-09.
These terms side by side for every vendor: data processing agreements compared. What vendors give you for a transfer impact assessment: transfer impact assessments.
AI and your data
What OpenAI's own pages state about the data you send its AI products, plan by plan. Compared with other vendors on AI vendors and your data.
| Plans | Term | What the page says | Source | Observed |
|---|---|---|---|---|
| Consumer ChatGPT, Sora, and Operator | Training on your data | Used unless you opt out content may be used to train models; users can opt out via privacy portal or settings; Temporary Chat not used for training | openai.com | 2026-10-28 |
| Business ChatGPT Business, Enterprise, Healthcare, Edu, Teachers | Training on your data | Not used unless you opt in not used for training by default unless the customer explicitly opts in to share data (e.g. feedback) | openai.com | 2026-10-28 |
| Business ChatGPT Business | Data retention | You set it workspace admins set retention; deleted or unsaved conversations removed within 30 days | openai.com | 2026-10-28 |
| Business ChatGPT Enterprise, Edu, Healthcare | Data retention | You set it workspace admins set retention; deleted conversations removed within 30 days | openai.com | 2026-10-28 |
| API API Platform | Training on your data | Not used unless you opt in not used for training by default (data after March 1, 2023) unless the customer explicitly opts in | openai.com | 2026-10-28 |
| API API Platform | Data retention | 30 days API inputs and outputs retained up to 30 days, then removed | openai.com | 2026-10-28 |
| API OpenAI API | Data retention | 30 days Abuse monitoring logs (may include prompts and responses) retained up to 30 days by default, longer if required by law or to prevent harm | developers.openai.com | 2026-10-28 |
| API API Platform | Zero data retention | On approval zero data retention on request for eligible endpoints with a qualifying use-case | openai.com | 2026-10-28 |
| API OpenAI API | Zero data retention | On approval Zero Data Retention or Modified Abuse Monitoring for eligible customers, subject to prior approval by OpenAI | developers.openai.com | 2026-10-28 |
| API OpenAI API | EU processing | In the EU Data residency with regional inference in supported regions (incl. Europe EEA + Switzerland); eligibility via sales, requires approved abuse monitoring controls for non-US regions | developers.openai.com | 2026-10-28 |
Assurance
Does OpenAI have a SOC 2 report?
OpenAI says a SOC 2 Type 2 report is available on request. We read this on 2026-10-05.
- Available on request “OpenAI's most recent SOC2 Report covers the period of January 1, 2025 to June 30, 2025 and is now available for viewing on the ChatGPT Business Products and API Trust Portal pages.”
- Available on request “Customers with active trust.openai.com accounts can access the latest report under "Compliance" > "SOC 2 Type 2."”
Source: trust.openai.com, 2026-10-05
Of the 114 vendors in this registry whose own pages mention SOC 2, 57 say the report is available on request, 1 links to the report itself, and 56 state it without saying how to get it. The type is the one the vendor names.
Is OpenAI ISO 27001 certified?
OpenAI states ISO/IEC 27001 certification (2022 edition, as OpenAI names it), and says the certificate or audit report is available on request. We read this on 2026-10-05.
- Available on request “conforms to the requirements of ISO/IEC 27001:2022 for OpenAI’s API, ChatGPT Enterprise, and ChatGPT Edu services”
Source: trust.openai.com, 2026-10-05
On the same list OpenAI also names ISO/IEC 27017, ISO/IEC 27018 and ISO/IEC 27701. Each standard's page says how it relates to ISO/IEC 27001.
Of the 122 vendors in this registry whose own pages state ISO/IEC 27001, 16 link to the certificate, 43 say it is available on request, and 63 state it without saying how to get it. A certificate names the certification body, the scope and the expiry date: those are the three things to check.
| Scheme | Status | Scope | Source | Observed |
|---|---|---|---|---|
| CCPA | Claimed | — | trust.openai.com | 2026-10-05 |
| CSA STAR · CSA | Claimed | — | trust.openai.com | 2026-10-05 |
| FedRAMP 20x · FedRAMP | Claimed | — | trust.openai.com | 2026-10-05 |
| GDPR | Claimed | — | trust.openai.com | 2026-10-05 |
| ISO/IEC 27001:2022 · ISO27001 | Available on request | OpenAI’s API, ChatGPT Enterprise, and ChatGPT Edu services | trust.openai.com | 2026-10-05 |
| ISO/IEC 27017:2015 · ISO27017 | Available on request | additional control sets, per the ISO/IEC 27001 certificate for OpenAI’s API, ChatGPT Enterprise, and ChatGPT Edu services | trust.openai.com | 2026-10-05 |
| ISO/IEC 27018:2019 · ISO27018 | Available on request | additional control sets, per the ISO/IEC 27001 certificate for OpenAI’s API, ChatGPT Enterprise, and ChatGPT Edu services | trust.openai.com | 2026-10-05 |
| ISO/IEC 27701:2019 · ISO27701 | Available on request | PIMS requirements, control implementation guidance, and additional control set | trust.openai.com | 2026-10-05 |
| ISO/IEC 42001:2023 · ISO42001 | Claimed | — | trust.openai.com | 2026-10-05 |
| PCI DSS v4.0.1 · PCIDSS | Claimed | — | trust.openai.com | 2026-10-05 |
| PCI-DSS · PCIDSS | Available on request | the components of ChatGPT that support delegated payment processing | trust.openai.com | 2026-10-05 |
| SOC2 | Available on request | Period January 1, 2025 to June 30, 2025; Security, Availability, Confidentiality, and Privacy Trust Services Criteria for the API Platform, ChatGPT Enterprise, ChatGPT Edu, and ChatGPT Team | trust.openai.com | 2026-10-05 |
| SOC 2 Type 2 · SOC2T2 | Available on request | Period July 1, 2025 to June 30, 2026; Security, Availability, Confidentiality, and Privacy Trust Services Criteria | trust.openai.com | 2026-10-05 |
| SOC 3 · SOC3 | Claimed | — | trust.openai.com | 2026-10-05 |
| TX-RAMP · TXRAMP | Claimed | — | trust.openai.com | 2026-10-05 |
Claimed means the vendor asserts the scheme on its own page and offers nothing further. Available on request means the report or certificate exists but sits behind a request, a login or an NDA. Neither is a certificate we have seen. That is a distinction an auditor makes, so we make it too.
SecNumCloud, C5, ENS and HDS for every vendor, with the pages for ISO standards, SOC 2 and TISAX: certifications compared.
Official registers
| Register | Offering, as the register names it | Status | Level | Valid until | Observed |
|---|---|---|---|---|---|
| FedRAMP Marketplace (US) | ChatGPT Enterprise and API Platform · OpenAI | FedRAMP Authorized | 20x Moderate | — | 2026-10-04 |
| Global LEI Index (GLEIF) | OPENAI OPCO, LLC · OPENAI OPCO, LLC | ISSUED | US-DE | 2027-02-27 | 2026-10-08 |
| GPAI Code of Practice signatories (European Commission) | General-Purpose AI Code of Practice (AI Act), as a provider of general-purpose AI models · OpenAI | signatory | — | — | 2026-11-09 |
- ACN qualified cloud (Italy): checked 2026-11-09, no entry under OpenAI; OpenAI Ireland Ltd.; OpenAI OpCo, LLC
- ISO 27001 on the basis of IT-Grundschutz (BSI, Germany): checked 2026-11-09, no entry under OpenAI; OpenAI Ireland Ltd.; OpenAI OpCo, LLC
- CISPE Data Protection Code of Conduct (GDPR Art. 40): checked 2026-11-09, no entry under OpenAI; OpenAI Ireland Ltd.; OpenAI OpCo, LLC
- DORA critical ICT third-party providers (ESAs): checked 2026-11-09, no entry under OpenAI; OpenAI Ireland Ltd.; OpenAI OpCo, LLC
- Data Privacy Framework List (US): checked 2026-11-09, no entry under OpenAI; OpenAI Ireland Ltd.; OpenAI OpCo, LLC
- ENS certificates of conformity (CCN, Spain): checked 2026-11-09, no entry under OpenAI; OpenAI Ireland Ltd.; OpenAI OpCo, LLC
- EU Cloud Code of Conduct (GDPR Art. 40): checked 2026-11-09, no entry under OpenAI; OpenAI Ireland Ltd.; OpenAI OpCo, LLC
- FedRAMP Marketplace (US): checked 2026-11-09, 1 entry under OpenAI; OpenAI Ireland Ltd.; OpenAI OpCo, LLC
- GPAI Code of Practice signatories (European Commission): checked 2026-11-09, 1 entry under OpenAI; OpenAI Ireland Ltd.; OpenAI OpCo, LLC
- SecNumCloud qualified services (ANSSI, France): checked 2026-11-09, no entry under OpenAI; OpenAI Ireland Ltd.; OpenAI OpCo, LLC
What the authority publishes, not what the vendor claims. An entry covers the offering it names and nothing else: a FedRAMP authorisation for a government edition says nothing about the commercial service. No entry is not a finding about security - most vendors never apply - and an entry filed under a name not listed above would not have been found.
What an entry on the Data Privacy Framework List covers, and which vendors hold one: EU-US Data Privacy Framework.
Support window
| Product | Support period | State | SBOM | Source | Observed |
|---|---|---|---|---|---|
| OpenAI API (SaaS) | — | Service only | unknown | openai.com | 2026-09-18 |
Vulnerability reporting: bugcrowd.com, [email protected] (security.txt, no Expires field; read 2026-10-17)
How other vendors publish theirs: security.txt across the registry.
Documents
Where is OpenAI's trust center?
OpenAI publishes a page it calls “Trust Portal” at trust.openai.com. Some of its documents sit behind a request or sign-in. The page mentions SOC 2, ISO 27001, a penetration test, subprocessors, security questionnaires and a DPA. We read it on 2026-11-03. Open trust.openai.com
- Name “Welcome to our Trust Portal for OpenAI's ChatGPT services, including ChatGPT Enterprise and ChatGPT Edu. Here, you can access our comprehensive”
- Request step “Get access”
Source: trust.openai.com, 2026-11-03. Read from the page's text, without a model; every vendor's trust center.
| Document | Disclosure | Transcription | HTTP | Observed |
|---|---|---|---|---|
| ai | Public | full | 200 | 2026-10-28 |
| ai-2 | Public | full | 200 | 2026-10-28 |
| ai-3 | Public | full | 200 | 2026-10-28 |
| dpa | Public | full | 200 | 2026-10-09 |
| subprocessors | Public | full | 200 | 2026-10-19 |
| tia | Public | full | 200 | 2026-10-20 |
History
| Detected | What moved | Why | Source |
|---|---|---|---|
| 2026-10-19 | Subprocessors removed Confluent; Intercom, Inc.; Okta, Inc. Subprocessors location changed Google Cloud Platform: FI, GB, JP, NL, NO, US -> FI, GB, JP, NL, NO, SG, US; Microsoft Corporation: AE, AU, BR, CA, CH, DE, ES, FR, GB, ID, IE, IN, IT, JP, KR, MX, NL, NO, PL, SE, SG, US, ZA -> AE, AU, BE, BR, CA, CH, DE, DK, ES, FR, GB, ID, IE, IN, IT, JP, KR, MX, MY, NL, NO, NZ, PL, SE, SG, US, ZA | the vendor changed it | openai.com |
| 2026-09-18 | EU data location Not stated → Paid upgrade Minimum plan set to Eligible customers, new Projects only Note rewritten | we read a better page | developers.openai.com |
Every reviewed change across the registry, newest first: vendor changes.