How to Request Deletion From an AI Vendor After an Exposure

Most AI exposures at a financial firm reach the same question from the CCO: can we get it back? Data cannot be pulled back from an AI vendor. The firm can file a deletion request with the vendor, such as an OpenAI data deletion request for ChatGPT, document it, and use the answer in the incident file. This walkthrough follows one hypothetical exposure from the deletion request to the records an examiner will want. If you are still in the first hour of an incident, start with what to do when someone pastes client data into an AI tool.

What does an AI exposure look like at an RIA?

Here is a hypothetical. An operations associate at an RIA uploads a spreadsheet of client names, account numbers and balances to a personal AI chatbot account to clean up the formatting. A colleague notices the next morning. The associate has already deleted the chat. The CCO now has to decide what to ask the vendor for, what the vendor will actually do, and whether clients need notice.

Under amended Regulation S-P, an SEC-registered adviser or broker-dealer must have an incident response program that assesses the nature and scope of an incident and takes appropriate steps to contain and control it. A deletion request to the AI vendor is one of those containment steps. It runs alongside the notice decision and does not replace it.

Does deleting the chat delete the data?

Usually not right away. Deleting a conversation removes it from the user's view and starts the vendor's own deletion schedule, which typically runs up to 30 days and has exceptions.

• OpenAI's privacy policy, updated September 10, 2026, says it removes deleted content from its systems within 30 days unless it must keep it longer. Its help center describes the same schedule for deleted ChatGPT chats.
• Anthropic says deleted conversations on consumer Claude plans are removed from back-end storage within 30 days. Content flagged by its trust and safety systems can be kept for up to two years, and chats already used in model training stay in models already trained.
• On Claude Enterprise, data is retained indefinitely by default unless an owner sets a custom retention period, which has a 30-day minimum.

Legal holds can override all of this. In 2025 a court preservation order in The New York Times' copyright case against OpenAI required OpenAI to keep deleted ChatGPT conversations from Free, Plus, Pro and Team users and from most API customers. OpenAI says those obligations ended on September 26, 2025 and that ChatGPT Enterprise and Edu were excluded. OpenAI also says it still stores a limited set of historical data from April to September 2025 that The New York Times continues to demand be preserved. For an incident file, the lesson is simple: a delete button shows the vendor's normal schedule, and a court order can still require the vendor to keep the data.

How do you submit a deletion request to an AI vendor such as OpenAI?

Use the vendor's formal privacy request channel in addition to deleting the chat, and send it from someone who controls the account. The steps depend on whose account it was.

If the exposure happened in a personal account

• Have the employee screenshot or export the conversations and uploaded files, then delete them.
• Have the employee turn off model training in the account settings so new and resumed chats are excluded.
• Have the employee submit a deletion request through the vendor's privacy channel. OpenAI's privacy policy lists privacy.openai.com and dsar@openai.com for these requests.
• If the account was opened only for work, decide whether the employee should delete the account entirely, and record the decision.

The firm cannot file a privacy request for an account it does not own. The employee has to make the request, with the firm supervising and keeping copies.

If the exposure happened in a firm business account

• An administrator exports the relevant audit log entries, then deletes the content with the plan's admin tools.
• Check the plan's retention setting. A business plan with long or indefinite retention keeps data until someone deletes it.
• Write to the vendor's support or privacy team, cite the contract, and ask for confirmation of deletion and of any logs or backups that will persist.

If your contract treats the AI vendor as a service provider under Regulation S-P, the rule's service provider provisions already require oversight, including notice to the firm within 72 hours of a breach affecting customer information in a system the vendor maintains. Use that contract language when you ask.

What should the deletion request say?

Keep it short and specific so the vendor can act on it and you can prove what you asked for.

• The account identifier (email or organization ID) and the plan type.
• The date and approximate time of the conversations or uploads.
• A request to delete the content, any uploaded files, and copies held in logs or backups on the vendor's normal schedule.
• A request to confirm whether the content was used, or is eligible to be used, for model training.
• A request for written confirmation of deletion and of any exceptions that apply, such as legal holds or safety retention.

Expect a template reply. OpenAI's privacy policy says it keeps an audit record of erasure requests to verify compliance. Ask for a reference number and save it.

Does a deletion confirmation mean clients don't need notice?

No. The notice decision under Regulation S-P turns on whether sensitive customer information was, or is reasonably likely to have been, accessed or used without authorization. A deletion confirmation is evidence for that analysis. It does not end the analysis.

Notice is due within 30 days of becoming aware of the incident unless the firm determines, after a reasonable investigation, that the information has not been and is not reasonably likely to be used in a way that would result in substantial harm or inconvenience (17 CFR 248.30(a)(4)). The SEC's adopting release describes a presumption of notification, so an inconclusive investigation does not support skipping notice. Waiting on a vendor reply does not pause the 30-day clock.

Retention details matter here. If the vendor kept the content for training, safety review or a legal hold, the firm has less basis to treat the exposure as contained. Counsel should weigh the vendor's answer alongside what was exposed and who could see the account.

What records should you keep?

Keep everything that shows what happened, what you asked the vendor to do, and how you reached the notice decision. SEC-registered advisers must keep Regulation S-P records under Rule 204-2(a)(25), and broker-dealers under Rule 17a-4(e)(14).

• Screenshots or exports of the exposed conversations taken before deletion.
• The deletion request, the date it was sent, and the vendor's reply or reference number.
• The vendor's published retention terms as of that date, saved as a PDF, since help pages change.
• Model training settings before and after the incident.
• The notice decision memo, including the investigation steps and who signed off.
• Any policy, training or technical changes made afterward.

What should you set up this quarter so the next request is faster?

Prepare now so the next deletion request takes minutes.

• List every AI tool staff use and record each vendor's deletion channel, retention period and training setting. Vet those terms before approving a tool.
• Add an AI vendor deletion request template to your Regulation S-P incident response procedures.
• Block personal AI accounts on firm devices so exposures land in accounts the firm controls.
• Set business plan retention deliberately, after confirming with compliance which AI records you must keep under the books and records rules.
• Run one tabletop exercise that ends with a vendor deletion request and a documented notice decision.

How can s90 help with AI vendor deletion requests?

s90 sets up AI platform policy enforcement and prompt monitoring so exposures are caught early and land in firm-controlled accounts. When one happens, we help your team run the vendor request and build the evidence trail. Our agreements commit us to notify you of a breach within 72 hours and to produce evidence within 24 hours. If you want a second look at your AI incident procedures, talk to our team.