AI Governance
Short answerIt depends on which account they use and what your own rules allow. OpenAI says it may use content from individual ChatGPT accounts to train its models unless the user opts out, while for business accounts it says it does not train on inputs or outputs by default, so the first rule most firms write is "firm accounts only".
This is one of the first questions a client asks, and the accurate answer is "it depends". What it depends on is something you control: which accounts your staff use, which settings are on, and what your written rules say may go in.
Personal and business accounts are not the same
OpenAI's own data page draws the line. For individual services like ChatGPT, it says it may use your content to train its models, and that you can opt out in your settings or through its privacy portal. For business products, including ChatGPT Team, ChatGPT Enterprise and the API, it says it does not train on inputs or outputs by default.
Vendors change these terms, so check the vendor's current page before you rely on it, and record the date you checked it.
Training is only one of the questions
Even on a business account, ask who at your firm can see past chats, how long the vendor keeps them, and whether your client contracts limit where their data may go. A client agreement can forbid something the vendor's settings would allow.
Rules most small firms start with
Firm accounts only; no personal AI accounts for client work. Remove client names, account numbers and tax IDs before asking for help with a formula or a summary. Read and correct anything AI-written before it goes to a client. Ask before using a new tool.
Write these down in one place and have staff sign them. A rule that lives only in a conversation is not a rule.
What this page does not do
It does not tell you whether a law or a client contract allows a particular use. That depends on your facts; ask your attorney.
Sources
- OpenAI: How your data is used to improve model performance (checked 2026-10-17)
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