OpenAI ChatGPT

Data-handling profile

Trains on input

Yes, on the consumer tier (enterprise tier excluded)

Retention

30 days (API); chat history used for training on Free/Plus unless opted out

Data region

US

Certifications

SOC 2 Type II

DPA available

Yes

Breach history

2023 Redis bug exposed some chat titles

EU AI Act

GPAI provider; transparency obligations apply

By plan and surface

Vendor-level answers are often wrong for a specific tier. These are the precise claims, each with the verbatim sentence we relied on.

• free/web: “We may use content from ChatGPT Free and Plus to improve our models.”
• pro/web: “We may use content from ChatGPT Free and Plus to improve our models.”
• enterprise/web: “We do not train on your business data by default.”
• api/api: “We do not train on inputs or outputs submitted through the API by default.”

Sources

• https://openai.com/enterprise-privacy

Every fact above is drawn from the vendor's public documentation, reviewed by a human, and version-stamped. Monitored daily for changes.

Control mapping

Obligations this vendor triggers, each attributable to the fact it rests on — for your supplier register, not a compliance determination.

• EU AI Act Art. 50 — Transparency obligations for AI systemsattention

  trains_on_input = all_tiers. Inputs may be reused for model training — users interacting with this system need to be informed accordingly.

• EU AI Act Art. 26 — Obligations of deployers of high-risk AI systemsapplies

  Applies to your organisation as deployer, independent of vendor. Assign human oversight, keep logs, and monitor operation where this tool is used in a high-risk context (Annex III duties apply from 2 Dec 2027).

• ISO/IEC 27001 A.5.19 — Information security in supplier relationshipsapplies

  OpenAI ChatGPT processes organisational data as a supplier. Include this vendor in the supplier register and risk assessment.

• ISO/IEC 27001 A.5.20 — Addressing information security within supplier agreementsok

  dpa_available = true. A data processing agreement is available and should be executed.

• ISO/IEC 27001 A.5.22 — Monitoring, review and change management of supplier servicesattention

  breach_history: 2023 Redis bug exposed some chat titles Prior incident on record — justify continued use and monitor.

• ISO/IEC 27001 A.5.23 — Information security for use of cloud servicesattention

  Cloud AI service; trains_on_input = all_tiers. Data submitted to this cloud service may be retained or reused — define acceptable-use rules for it.

• ISO/IEC 42001 A.10.3 — Suppliers of AI systems and servicesapplies

  certifications: SOC 2 Type II No AI-management certification identified; assurance must come from your own supplier assessment.

• GDPR Art. 44–49 — International transfers of personal dataattention

  data_region = US. Processing occurs outside the EU/EEA — a transfer mechanism (SCCs or adequacy) must be in place.

• NIS2 Art. 21(2)(d) — Supply chain securityapplies

  AI vendor forms part of your ICT supply chain. In scope for entities covered by NIS2; include in supply-chain risk measures.

• DORA Art. 28 — General principles for ICT third-party riskapplies

  AI vendor is an ICT third-party service provider. For financial entities: register of information and contractual requirements apply.

Change history

No material changes recorded since monitoring began.