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OpenAI Subprocessor FAQ

We are adding OpenAI to the list of our subprocessors and are providing notice to Tilt customers. We know you may have some questions, so check out the article below to learn more.

Why am I getting an email about a subprocessor being added?

To be transparent about how Tilt uses your data, we maintain documents like Tilt’s Subprocessor List. When new subprocessors are added to this list, we notify you to let you know about what is being changed. The email you received is an example of this kind of notification.

OpenAI is an industry leader in AI, and Tilt will use its service to provide AI-powered functionality that enhances our leave management platform. We’re including OpenAI as a subprocessor as new functionality we’re building uses data which can sometimes include customer data.

Your data will be used as part of prompts sent to OpenAI to generate content and insights for AI-powered features in the Tilt platform. The data from your Tilt account is exclusively used to generate content for your own organization, and not for other users of the Tilt platform. We also use AI to better understand your needs as a Tilt customer, such as identifying feature improvements or request trends in support tickets.

 

Tilt uses OpenAI to enhance various aspects of our leave management platform, including:

  • Development tools for building and improving our platform
  • Internal process automation for support ticket analysis and operational efficiency
  • Research and analysis to improve our leave management solutions
  • Team collaboration features powered by AI assistance

No. OpenAI will never be used to make leave decisions or legal determinations. All leave decisions remain subject to human review and our established compliance processes. This ensures we maintain full compliance with Department of Labor regulations and state AI laws.

If you don’t actively use AI-powered features, the only time we’ll send your data to OpenAI is for internal use at Tilt, such as analyzing support feedback, identifying trends in support tickets, and improving our platform’s performance.

Your data is not used to train OpenAI’s models. When generating content using AI, OpenAI temporarily stores data for a short period of time for preventing abuse of their platform, though otherwise does not retain nor use your data. We have configured all OpenAI settings to explicitly prohibit training on Tilt or customer data.

Your sensitive leave management data, including FMLA information, medical certifications, and employee personal details, remains protected under the same security standards. Any data processed through OpenAI is subject to:

  • Data minimization protocols that strip unnecessary PII before processing
  • Secure processing environments using company-managed OpenAI Business accounts
  • Human oversight requirements for all AI-generated outputs

Yes. We will maintain a list of customers who choose to opt out of OpenAI processing. If you prefer that your organization’s data not be processed by OpenAI, please contact our team. We will ensure that no OpenAI features are used in connection with your account.

OpenAI has passed our comprehensive security review process and maintains:

  • SOC 2 Type 2 compliance
  • Data encryption at rest and in transit

Our use of OpenAI is designed to enhance, not replace, our compliance assistance processes. All leave determinations continue to follow established legal frameworks, and AI is used only for supportive functions like documentation assistance and process improvement, never for making compliance decisions.

This change is effective 10/31/2025. However, if you have concerns or wish to opt out, please contact our team as soon as possible to discuss your options.

If you have additional questions about our use of OpenAI or data privacy practices, please contact us at security@ourtilt.com.