OpenAI
openai.com
Automated, point-in-time. Not independently reviewed or approved by TRUSTYCYBER unless expressly stated.
Scanned Aug 28, 2026 · Public evidence · Point-in-time
Higher scores indicate stronger, independently supported AI assurance — governance, AI systems, models, data, supply chain and third-party assurance evidence. The score and the decision are related but different: a well-scored vendor can still carry conditions.
Buyer questionsanswered only from the public evidence scanned — click a row for the answer
✓Will they train on your data?Clear
OpenAI states it does not train its models on business/organisation data by default.
“train our models on your organization’s data by default.”
✓How long do they keep your data?Clear
Workspace admins control retention for ChatGPT Enterprise/Edu/Healthcare; deleted conversations leave OpenAI systems within 30 days unless legally required.
“Your workspace admins control how long your data is retained. Any deleted conversations are removed from our systems within 30 days,”
“return or delete Customer Data, and existing copies unless retention of Customer Data is required under applicable laws,”
!Who else can access your data?Ask the vendor
OpenAI publishes a dated sub-processor list with entity, product, processing location and purpose.
Confirm in writing: Ask the vendor to state this in writing before signing.
“OpenAI engages the following entities to provide processing activities for Customer Data (as defined in the OpenAI Data Processing Agreement).”
“Sharing with the Sub-processor platform only occurs when content is flagged, the Sub-processor platform only retains samples of content for the period of review,”
✓Where is your data processed?Clear
Data residency is available for ChatGPT and the API among enterprise compliance features.
“data residency for ChatGPT (opens in a new window) and API”
✓What happens in a security incident?Clear
The security team runs a 24/7/365 on-call rotation paged for potential incidents, alongside a bug bounty programme for responsible disclosure.
“Our security team has an on-call rotation that has 24/7/365 coverage and is paged in case of any potential security incident. We offer a Bug Bounty Program”
Key findingsclick a row for the evidence
✓Certification stack now spans security, privacy and AI managementStrong
SOC 2 Type 2 (API), ISO 27001 and 27701, and an ISO/IEC 42001 AI management system covering consumer and business AI products.
42001 over the AI products directly is still rare and answers the AI-governance question at certification grade.
“API Platform has been audited and certified for SOC 2 Type 2 compliance.”
“OpenAI maintains ISO/IEC 27001:2022 and ISO/IEC 27701:2019 certifications for the information security and privacy management systems supporting the OpenAI API, ChatGPT Enterprise, and ChatGPT Edu services.”
“OpenAI maintains an ISO/IEC 42001:2023 AI Management System covering OpenAI’s consumer and business AI products and models”
!Data commitments hinge on defaults and plan tierGap
No-training applies to business data by default; retention is admin-controlled on enterprise plans. Consumer plans differ.
Which surface employees actually use determines the live posture.
Question for vendor: Confirm plan tier in use and that training-off and retention controls apply to it.
“train our models on your organization’s data by default.”
“Your workspace admins control how long your data is retained. Any deleted conversations are removed from our systems within 30 days,”
!CSA STAR is Level 1 (self-assessment)Gap
The STAR registry evaluation cited is Level 1 transparency self-assessment, not the third-party-assessed Level 2.
Level 1 is disclosure, not independent assurance; the SOC 2/ISO set carries the independent weight.
“OpenAI maintains PCI-DSS compliance for the components of ChatGPT that support delegated payment processing.”
✓Moderation sharing is disclosed with boundsStrong
Flag-triggered moderation sharing with retention limited to the review period is disclosed on the sub-processor register itself.
The one data flow buyers most often discover late is documented up front.
“Sharing with the Sub-processor platform only occurs when content is flagged, the Sub-processor platform only retains samples of content for the period of review,”
?Technical dependency observed: OpenAIObservation
Technical evidence (DNS, certificate, or HTTP) shows a dependency on OpenAI as a model provider. This dependency is not identified in the vendor's published materials.
An undisclosed provider dependency is exactly the gap independent verification exists to surface.
Question for vendor: Verification required — OpenAI appears to be involved as a model provider: confirm whether this dependency exists, and whether it processes customer data.
“OpenAI engages the following entities to provide processing activities for Customer Data (as defined in the OpenAI Data Processing Agreement).”
“Sharing with the Sub-processor platform only occurs when content is flagged, the Sub-processor platform only retains samples of content for the period of review,”
?Technical dependency observed: MicrosoftObservation
Technical evidence (DNS, certificate, or HTTP) shows a dependency on Microsoft as a service provider. This dependency is not identified in the vendor's published materials.
An undisclosed provider dependency is exactly the gap independent verification exists to surface.
Question for vendor: Verification required — Microsoft appears to be involved as a service provider: confirm whether this dependency exists, and whether it processes customer data.
“OpenAI engages the following entities to provide processing activities for Customer Data (as defined in the OpenAI Data Processing Agreement).”
“Sharing with the Sub-processor platform only occurs when content is flagged, the Sub-processor platform only retains samples of content for the period of review,”
?Technical dependency observed: GoogleObservation
Technical evidence (DNS, certificate, or HTTP) shows a dependency on Google as a service provider. This dependency is not identified in the vendor's published materials.
An undisclosed provider dependency is exactly the gap independent verification exists to surface.
Question for vendor: Verification required — Google appears to be involved as a service provider: confirm whether this dependency exists, and whether it processes customer data.
“OpenAI engages the following entities to provide processing activities for Customer Data (as defined in the OpenAI Data Processing Agreement).”
“Sharing with the Sub-processor platform only occurs when content is flagged, the Sub-processor platform only retains samples of content for the period of review,”
?Technical dependency observed: AtlassianObservation
Technical evidence (DNS, certificate, or HTTP) shows a dependency on Atlassian as a service provider. This dependency is not identified in the vendor's published materials.
An undisclosed provider dependency is exactly the gap independent verification exists to surface.
Question for vendor: Verification required — Atlassian appears to be involved as a service provider: confirm whether this dependency exists, and whether it processes customer data.
“OpenAI engages the following entities to provide processing activities for Customer Data (as defined in the OpenAI Data Processing Agreement).”
“Sharing with the Sub-processor platform only occurs when content is flagged, the Sub-processor platform only retains samples of content for the period of review,”
?Technical dependency observed: StripeObservation
Technical evidence (DNS, certificate, or HTTP) shows a dependency on Stripe as a service provider. This dependency is not identified in the vendor's published materials.
An undisclosed provider dependency is exactly the gap independent verification exists to surface.
Question for vendor: Verification required — Stripe appears to be involved as a service provider: confirm whether this dependency exists, and whether it processes customer data.
“OpenAI engages the following entities to provide processing activities for Customer Data (as defined in the OpenAI Data Processing Agreement).”
“Sharing with the Sub-processor platform only occurs when content is flagged, the Sub-processor platform only retains samples of content for the period of review,”
Assurance dimensionsweighted components of one score — not eight separate ratings
Organisation & AI governance15% of the score60
Who owns AI risk — policies, responsible-AI principles, human oversight and administrative controls.
Assessed against ISO 42001 · NIST AI RMF · AIUC-1
“—including these Usage Policies—set a reasonable bar for acceptable use.”
AI system15% of the score27
What AI the vendor actually runs and where it sits in the product — the map everything else is judged against.
Assessed against ISO 42001 · NIST AI RMF
“Our commitments provide you with ownership and control over your business data (inputs and outputs from ChatGPT Business, ChatGPT Enterprise, ChatGPT for Healthcare, ChatGPT Edu, ChatGPT for Teachers and our API Platform)”
How AI features are evaluated before and after release — evals, red-teaming, monitoring.
Assessed against NIST GenAI · NIST AI RMF · ISO 42001
“We protect your data with thorough testing and monitoring validated by independent auditors.”
How changes to models and AI features are controlled and communicated — versioning, notice, rollback.
Assessed against ISO 27001 · ISO 42001
Change management: not publicly evidenced.
Model10% of the score40
Which model providers and versions process customer data, and how changes to them are disclosed.
Assessed against NIST GenAI · ISO 42001
“OpenAI maintains an ISO/IEC 42001:2023 AI Management System covering OpenAI’s consumer and business AI products and models”
“Sharing with the Sub-processor platform only occurs when content is flagged, the Sub-processor platform only retains samples of content for the period of review,”
Customer data15% of the score77
Whether customer data trains models, how long it is retained, where it is processed, and how it is protected.
Assessed against ISO 27018 · OAIC APPs · EU AI Act
“train our models on your organization’s data by default.”
“Your workspace admins control how long your data is retained. Any deleted conversations are removed from our systems within 30 days,”
“Your content is encrypted at rest and in transit between you and OpenAI, and between OpenAI and its service providers.”
“data residency for ChatGPT (opens in a new window) and API”
“return or delete Customer Data, and existing copies unless retention of Customer Data is required under applicable laws,”
Customer data treatment: the certifications above are independently corroborated, but they cover the management system — these specific disclosures are the vendor's own statements, not yet independently verified.
AI supply chain10% of the score60
The named chain of AI and infrastructure providers behind the product, and how it is disclosed.
Assessed against ISO 27001 · ISO 27017
“OpenAI engages the following entities to provide processing activities for Customer Data (as defined in the OpenAI Data Processing Agreement).”
“Sharing with the Sub-processor platform only occurs when content is flagged, the Sub-processor platform only retains samples of content for the period of review,”
Subprocessors & supply chain: vendor-evidenced, not yet independently corroborated.
Security foundation15% of the score85
How security problems are found, reported and handled — disclosure channels, bug bounty, incident response.
Assessed against ISO 27001 · NIST AI RMF
“Our security team has an on-call rotation that has 24/7/365 coverage and is paged in case of any potential security incident. We offer a Bug Bounty Program”
Vulnerability & incident handling: the certifications above are independently corroborated, but they cover the management system — these specific disclosures are the vendor's own statements, not yet independently verified.
Independent assurance evidence10% of the score100
Whether claimed certifications and attestations are independently corroborated — checked against official registries and issuing bodies. Which certifications, and what each one does and does not establish, is stated per certificate.
Assessed against ISO 17021-1 · ISO 42006 · ISO 27006-1 · ISO 27008
“API Platform has been audited and certified for SOC 2 Type 2 compliance.”
“OpenAI maintains ISO/IEC 27001:2022 and ISO/IEC 27701:2019 certifications for the information security and privacy management systems supporting the OpenAI API, ChatGPT Enterprise, and ChatGPT Edu services.”
“OpenAI maintains an ISO/IEC 42001:2023 AI Management System covering OpenAI’s consumer and business AI products and models”
“OpenAI maintains PCI-DSS compliance for the components of ChatGPT that support delegated payment processing.”
Document held and reviewed by TrustyCyber — cited, not reproduced.
Read from the registry record above — cited, not reproduced.
Document held and reviewed by TrustyCyber — cited, not reproduced.
Read from the registry record above — cited, not reproduced.
Read from the registry record above — cited, not reproduced.
Read from the registry record above — cited, not reproduced.
Read from the registry record above — cited, not reproduced.
Document held and reviewed by TrustyCyber — cited, not reproduced.
Document held and reviewed by TrustyCyber — cited, not reproduced.
Read from the registry record above — cited, not reproduced.
Legal & contractual10% of the score60
The contractual backbone a buyer can rely on — terms, DPAs, privacy commitments and regulatory posture.
Assessed against EU AI Act · OAIC APPs
“return or delete Customer Data, and existing copies unless retention of Customer Data is required under applicable laws,”
“—including these Usage Policies—set a reasonable bar for acceptable use.”
“automation of high-stakes decisions in sensitive areas without human review”
Legal & contractual transparency: vendor-evidenced, not yet independently corroborated.
Not graded: Agent — not applicable to this scan.
What would strengthen assuranceeach figure is from today's score — resolving one changes the others
Resolving an evidence gap strengthens the dimension it belongs to, and with it the score: 63 → up to 81 with every identified gap resolved.
AI supply chainclick a node to focus it · drag to pan · zoom with the controls
View as list
What you inheritTrustyCyber's AI Shared Responsibility Matrix v1.0
This scan names the vendor’s AI supply chain without assessing the responsibility split — that depends on how you consume the product. Under the common managed models, a deployer inherits 16 of the matrix’s 41 responsibilities from providers, each with named evidence owed.
Map your inherited responsibilitiesAssurance evidence: certifications 10 — registry checks and verification ladders, click to view
SOC 2 Type 2 for the API Platform and ChatGPT business services; reports via the trust portal.
Checked against SOC 2 Type 2 report held in the TrustyCyber vault (OpenAI trust portal), Aug 28, 2026: Verified on the registry
ISO/IEC 27001:2022 for systems supporting the API, ChatGPT Enterprise and Edu.
Checked against ISO/IEC 27001:2022 certificate held in the TrustyCyber vault (OpenAI trust portal), Aug 24, 2026: Verified on the registry
ISO/IEC 27701:2019 is corroborated as an EXTENSION WITHIN OpenAI's ISO/IEC 27001:2022 certificate 1404936-1 (Schellman, ANAB), not as a standalone 27701 certificate. The certified scope extends to the PIMS requirements and additional control set of 27701:2019 in the role of a PII processor, covering the API, ChatGPT Enterprise and ChatGPT Edu services; SoA v2 dated 29 May 2025.
Checked against IAF CertSearch, Aug 24, 2026: Verified on the registry
AI management system covering consumer and business AI products and models.
Checked against ISO/IEC 42001:2023 certificate held in the TrustyCyber vault (OpenAI trust portal), Aug 24, 2026: Verified on the registry
Delegated payment components of ChatGPT.
Checked against PCI DSS v4.0.1 Attestations of Compliance (Service Providers and Merchants), OpenAI trust portal download supplied by Robbo 2026-08-28, Aug 28, 2026: Verified on the registry
Level 1 self-assessment, not third-party assessed.
Checked against CSA STAR Registry, Aug 28, 2026: Verified on the registry
SOC 2 Type 2 by Schellman & Company, period 1 Jan - 30 Jun 2025, system: API and ChatGPT Business Product Services; trust services criteria security, availability, confidentiality AND privacy (four - broader than Perplexity's three, which omit privacy). SCOPE IS THE BUSINESS OFFERINGS ONLY, the same boundary as OpenAI's ISO/IEC 27001 certificate; consumer ChatGPT is outside it. NOTE FOR BUYERS: this is the SAME ENGAGEMENT as the already-corroborated SOC 3, which is its general-use summary - they are one attestation reported two ways, not two independent ones. The period ended 30 Jun 2025, so the report is over a year old; ask for the current period or a bridge letter. Vault: Gated/OpenAI/2025-06_openai-soc2-type2-schellman.pdf.
Checked against SOC 2 Type 2 report held in the TrustyCyber vault (OpenAI trust portal), Aug 24, 2026: Verified on the registry
Checked against CSA STAR Registry, Aug 28, 2026: Verified on the registry
SOC 3 Type 2, period 1 Jan 2025 - 30 Jun 2025, unqualified; trust services criteria security, availability, confidentiality and privacy. System: API and ChatGPT Business Product Services - BUSINESS OFFERINGS ONLY, the same boundary as OpenAI's ISO/IEC 27001 certificate; consumer ChatGPT is outside it. TWO LIMITATIONS A BUYER SHOULD WEIGH: the period ended 30 June 2025, so the report is over a year old and procurement would normally ask for the current period or a bridge letter; and a SOC 3 does NOT substitute for the SOC 2 Type 2 that OpenAI separately claims - it derives from that engagement but is a different report, so the SOC 2 claim stays uncorroborated. Vault: Gated/OpenAI/2025_openai-soc-3-report.pdf.
Checked against SOC 3 Type 2 report held in the TrustyCyber vault (OpenAI trust portal), Aug 24, 2026: Verified on the registry
Checked against FedRAMP Marketplace (fedramp.gov), Aug 28, 2026: Verified on the registry
Sources 22 — click to view
Appendix: standards landscape 8 — click to view
Where each standard behind this assessment stands today, from TrustyCyber’s continuously maintained standards radar.
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