Product and intended use
Define the configuration, people, information and tasks being assessed.
Plan in scope
Public claim only
This profile covers ChatGPT Enterprise (not Business, Edu, Healthcare, consumer ChatGPT or the API). Astra for Law (announced 17 Sep 2026) is GPT-6 Astra with a US legal search index and legal plugins; help documentation says it is initially offered to selected US law firms through Trusted Access and Codex, with API access coming soon. ChatGPT Work and Codex are Enterprise features that can take actions across apps.
Ask: Confirm our workspace is ChatGPT Enterprise (not Business), whether Astra for Law / GPT-6 Astra Law is enabled, and which of ChatGPT Work, Codex, apps and plugins are in the order form.
Deployment and residency
Public claim only
ChatGPT Enterprise is multi-tenant SaaS. Eligible new Enterprise/Edu customers can select data residency (storage at rest) in Australia among other regions. Inference residency (GPU execution in-region) is listed only for Europe, the United States and the UAE, and requires data residency in the same region. Australian storage is therefore not an Australian inference guarantee. Apps, web search, metadata, billing and logins may sit outside the selected region.
Ask: Record our Data Residency Region and Inference Residency Region in writing, and list every feature that is out of scope for those settings.
Legal features
Public claim only
Astra for Law searches US case law, statutes, regulations, court rules and administrative decisions (230 million+ URLs; Free Law Project / CourtListener coverage of published US precedential case law). Partner plugins include iManage, Relativity, Clio, Thomson Reuters, Harvey and Legora. It is not described as covering Australian primary law. OpenAI reports 54.0% all-pass on 200 US questions from Vals AI Legal Research Bench versus 38.7% for GPT-6 Astra with web search alone.
Ask: Is Astra for Law available to an Australian workspace, and does the legal search index include any Australian authorities?
Australia
Public claim only
Australian storage residency is available for eligible Enterprise workspaces. Inference residency is not listed for Australia as at 20 Sep 2026. Astra for Law Trusted Access is described as US law firms. No Australian law-firm customer was named on the Astra announcement (US firms were named).
Ask: Can our Australian entity obtain AU data residency on this workspace, and is Astra for Law licensed for use from Australia?
Data, controls and requirements
Compare the actual configuration with firm, client and jurisdiction requirements, supported by evidence.
Client-facing use
Not confirmed
Astra help: access is for eligible lawyers and people working under their supervision (Trusted Access). ChatGPT Enterprise itself can be given to any employee. No Australian client-disclosure templates were found. GPTs can be published externally if admins allow (not for Healthcare).
Ask: Will public GPT sharing be disabled, and is use limited to admitted practitioners and supervised staff?
Model provider
Public claim only
OpenAI is the model provider (GPT-5-class models, GPT-6 Astra, Codex). Microsoft, CoreWeave, Oracle, Google Cloud, AWS and Cerebras appear as cloud-infrastructure subprocessors, which is hosting rather than a substitute model vendor.
Ask: List model IDs enabled for our workspace (including whether GPT-6 Astra Law is on) and whether any request is routed to a non-OpenAI model.
Subprocessors
Public claim only
List updated 9 Jul 2026 names Cloudflare, Microsoft (including Australia), CoreWeave, Oracle, GCP, AWS, Cerebras, Snowflake, TaskUs (Philippines — GPT moderation on Enterprise/Edu/Business), Intercom, Salesforce, Pylon, Accenture, Cinder, WorkOS, Okta, Merge API (connectors, customer election). Subscribe form for new subprocessors. Moderation samples of flagged content may be shared with subprocessors.
Ask: Provide notice/objection rights in our DPA, and confirm TaskUs/Accenture will not receive our privileged chats unless we enable public GPTs or file a support case.
Training
Public claim only
Services Agreement 4.2: OpenAI will not use Customer Content to develop or improve the Services unless Customer explicitly agrees. Enterprise privacy: no training on business data by default; opt-in feedback mechanisms are the exception. Fine-tuned models (API) are not shared with other customers.
Ask: Confirm the signed agreement contains the no-training clause for prompts, files, outputs, embeddings and logs, with no workspace-level opt-in left on.
Feedback
Public claim only
Enterprise privacy FAQ: if the customer explicitly opts in through feedback mechanisms, shared data may be used to train. Default is off for business data.
Ask: Disable all training-related feedback sharing for our Enterprise workspace and confirm historical feedback (if any) is excluded.
Retention
Public claim only
Enterprise admins control how long data is retained. Deleted conversations are removed within 30 days unless legally required. Shorter retention may reduce conversation history. API (separate product) may retain inputs/outputs up to 30 days for abuse monitoring unless ZDR is approved.
Ask: Set our Enterprise retention period in the workspace and contract, including backups, Compliance API logs and any Astra index caches.
Deletion
Public claim only
Deleted conversations: 30 days. DPA deletion/return terms apply (inspect the signed DPA for the exact period; this review's DPA scrape states breach notice and processing terms; confirm the deletion schedule in the executed copy). No sample deletion certificate was published.
Ask: Confirm matter-level deletion, backup purge lag, embeddings, and a deletion certificate within 30 days of exit.
Vendor staff access
Public claim only
Enterprise FAQ: authorized OpenAI employees access conversations only to resolve incidents, recover conversations with explicit customer permission, or where required by law. TaskUs may moderate GPTs. Business (not Enterprise) FAQ additionally describes specialized third-party contractors reviewing for abuse — do not assume that broader contractor review applies to Enterprise.
Ask: Confirm in writing that no third-party moderator reads our Enterprise chats unless we open a support case or enable public GPTs, and that employee access is logged to us.
SSO and admin
Public claim only
SAML SSO, feature access controls, admin control of agents/tools/actions, Compliance API. WorkOS for identity. Lockdown Mode is referenced from the residency article as a way to disable external search.
Ask: Enable SSO-only, SCIM if available, Lockdown Mode or equivalent web-search off, and exportable audit logs for 12 months.
Encryption
Public claim only
Enterprise privacy: AES-256 at rest and TLS 1.2+ in transit between customers, OpenAI and service providers. No customer-managed key option was found on the public Enterprise pages reviewed.
Ask: Confirm encryption of chats, files, embeddings, backups and log stores, and whether BYOK is available.
Assurance
Public claim only
Trust Portal: SOC 2 Type 2; ISO 27001, 27017, 27018 and 27701; CSA STAR; PCI DSS; bug bounty on Bugcrowd. Services Agreement: audit reports once per year on request, treated as OpenAI confidential. Reports were not inspected. ISO/IEC 42001 was not listed.
Ask: Provide under NDA the current SOC 2 Type II and ISO certificates scoped to ChatGPT Enterprise and Astra for Law, with exceptions and a bridge letter.
Contract
Public claim only
OpenAI Services Agreement (1 Jan 2026) plus DPA. Customer owns Input and Output. Customer Content is Confidential Information. IP indemnity for the Services (exclusions apply); Service-Specific Terms Indemnity uncapped as of the Effective Date. Liability cap: fees in prior 12 months, with carve-outs for gross negligence/willful misconduct, indemnities, and (for indirect damages) confidentiality and security-measures breaches. Australian customers: California law; arbitration/venue San Francisco. Material feature reduction: customer may terminate with notice.
Ask: Execute the DPA, confirm Customer Content is confidential, and negotiate Australian law/forum and a higher cap for privacy/security breach if required.
Cross-border transfers
Public claim only
AU data residency stores listed customer content in Australia; inference may still run outside Australia unless a supported inference region is selected (AU is not on that list). Microsoft Azure subprocessors include Australia. Web search and apps can leave the region. DPA includes SCCs. Breach notice is without undue delay, not a stated 48- or 72-hour clock.
Ask: Complete an APP 8 map for storage versus inference versus apps versus support, and confirm SCC execution.
Incidents
Public claim only
DPA 2.7: notify Customer without undue delay after becoming aware of a Personal Data Breach, with reasonable assistance. 24/7 security on-call is claimed on the enterprise privacy page. Bug bounty exists. No 48-hour contractual clock was found. No public Enterprise incident register was inspected.
Ask: Will you contract a maximum 72-hour (preferably 48-hour) notice with NDB-usable content and no gag on notifying the OAIC or clients?
Changes
Public claim only
Services Agreement: OpenAI may update Services; material functional reduction triggers a termination right. Pricing Page changes effective in 14 days. Subprocessor subscribe form. Astra for Law launched 17 Sep 2026. Auto-renewal depends on the order form (30-day notice to reduce or non-renew).
Ask: What notice before a default model or legal-index change, and is auto-renewal off unless we confirm?
Exit
Public claim only
Effects of termination are in the Services Agreement (export/return details should be read in section 11 of the signed copy). Deleted conversations: 30 days. Compliance API can export conversation audit data during the term. No escrow was found.
Ask: Provide export of conversations, files, GPTs, plugin configs and audit logs in open formats, then certified deletion within 30 days.
Apps, plugins and MCP
Public claim only
Admins control apps. Data from apps is not used for training by default. Merge API processes connector data at customer election. Astra plugins (iManage, Relativity, Clio and others) send matter context into ChatGPT. External integrations are outside data-residency scope.
Ask: List every app and plugin that will be on, the data each sends, and confirm unused connectors stay off.
Web search
Public claim only
External search remains available unless Lockdown Mode or workspace search controls disable it. Web search is outside the selected residency region. Astra for Law's legal index is a separate corpus from open web search.
Ask: Disable web search / Lockdown Mode for privileged workspaces, and confirm legal-index queries are not sent to the open web.
Agents and ChatGPT Work
Not confirmed
ChatGPT Work can plan and take action across apps and files, including long-running projects. Admins can manage who can use agents, connected tools and actions. OpenAI may suspend for security emergency or policy breach. No timed customer kill-switch for in-flight Work agents was documented on the pages reviewed.
Ask: Which actions require human confirm before send/share/delete, and how do we immediately revoke agents and API-connected apps?
Human oversight
Public claim only
Services Agreement 4.3 requires the customer to evaluate Output. Astra help: review answers and cited sources before relying on them. Compliance API gives admins an audit log of conversations. The product does not force a review gate.
Ask: Can we export per-user conversation metadata to our SIEM for 12 months, and is there any forced review step before export to Word or iManage?
