Product and intended use
Define the configuration, people, information and tasks being assessed.
Chat-only Entra versus licensed Microsoft 365 Copilot
Public claim only
This profile is Copilot Chat with an Entra account and no Microsoft 365 Copilot add-on. EDP (DPA and Product Terms) covers prompts and responses. Unlike licensed Copilot, Chat is not Graph-grounded in the chat experience unless the user pastes/uploads a file, uses Chat in Outlook, or uses a pay-as-you-go agent. Consumer Copilot and licensed Copilot need separate profiles.
Ask: Confirm users are Entra-signed-in Chat-only, and list which agents or Outlook Chat access are enabled.
Microsoft 365 service boundary; Bing is outside it
Public claim only
Prompts and responses are processed within the Microsoft 365 service boundary with EDP. Web grounding sends short Bing queries without user or tenant identifiers. Bing operates under the Microsoft Services Agreement as a separate controller. Anthropic models, if enabled, are excluded from the EU Data Boundary and in-country processing.
Ask: Is web search on, is ADR/Multi-Geo in place, and are Anthropic or OpenAI model routes enabled?
Web-grounded chat; optional file/Outlook/agent grounding
Public claim only
Users prompt from web, Copilot app, Teams or Outlook. Grounding is web-only unless content is added in the prompt, Chat is used in Outlook (mail, calendar, chats, limited OneDrive/SharePoint), or a pay-as-you-go agent with organisational content is used. Multiple models may generate a response. Interactions are logged to Exchange before the reply is shown.
Ask: Will Outlook Chat and file upload be allowed, and which agents can see tenant files?
EDP in M365 geo; Bing and Anthropic exceptions
Public claim only
EDP commitments (GDPR, ISO 27018, DPA, EU Data Boundary footnote) apply to prompts and responses. EU Data Boundary does not apply to web search queries. Anthropic models are currently excluded from the EU Data Boundary. HIPAA, where configured, does not apply to web search queries.
Ask: Map APP 8 for Exchange-stored chats, Bing queries and any Anthropic/OpenAI route for our AU tenant.
Data, controls and requirements
Compare the actual configuration with firm, client and jurisdiction requirements, supported by evidence.
Internal chat; uploads and Outlook expand the corpus
Not confirmed
Default Chat does not search the firm's files. Uploading a client document, using Outlook Chat, or enabling an agent brings that content into prompts stored in Exchange and, if web search is on, into Bing query generation. No AU client-disclosure template was found.
Ask: How will we disclose Copilot Chat use, file upload and Outlook grounding to clients?
Microsoft models; optional Anthropic/OpenAI
Public claim only
Copilot Chat may use multiple models. Admins can enable Anthropic and OpenAI as AI subprocessors; additional terms apply and Anthropic is excluded from the EU Data Boundary. Restricting to Microsoft-hosted models is an admin choice.
Ask: Which model providers are enabled for Copilot Chat in our tenant?
Online Services plus optional AI subprocessors; Bing separate
Public claim only
Microsoft Online Services subprocessors apply under the DPA for prompts/responses. Optional Anthropic and OpenAI AI subprocessors. Bing web search is a separate controller under the Services Agreement and Privacy Statement, with extra Product Terms commitments for generated search queries.
Ask: Provide the Copilot Chat subprocessor extract and confirm Bing, Anthropic and OpenAI on or off.
No foundation-model training for prompts, responses or Graph
Public claim only
EDP and Copilot Chat privacy: prompts, responses and Graph data are not used to train foundation models. Bing web queries are also stated not to train foundation LLMs and not to be shared with advertisers.
Ask: Confirm the no-training commitment in our Product Terms for Chat, including any Anthropic/OpenAI route.
Optional Microsoft 365-style feedback
Not confirmed
Chat-specific feedback controls were not extracted from the pages reviewed. Organisational Copilot documentation allows admins to manage optional feedback, which Microsoft says is not used to train foundation models.
Ask: Disable optional Copilot feedback for Entra users if we do not want interaction content in the improvement channel.
Logged in Exchange; Purview policies apply
Public claim only
Before the response is returned, prompt and response are stored in Exchange for auditing/eDiscovery. Retention, audit and labels apply according to the underlying Microsoft 365 plan. Default Copilot interaction retention should be confirmed in Purview.
Ask: What is the Copilot interaction retention label in our tenant, and can we set 30 days?
Follows Microsoft 365 / DPA offboarding
Not confirmed
Deletion of Exchange-stored Copilot interactions follows Microsoft 365 content deletion and the DPA. This review did not extract a Chat-specific certified-deletion day count. Bing query copies are outside that store.
Ask: Confirm Chat prompts/responses in Exchange and any agent logs are deleted with our Microsoft 365 data on instruction.
Microsoft 365 support practices; Lockbox if purchased
Public claim only
EDP cites physical security, encryption and tenant isolation. Customer Lockbox is an eligible Microsoft 365 add-on — confirm whether it covers Copilot Chat support access.
Ask: Is Customer Lockbox in our SKU for Copilot Chat-related support?
Entra identity and plan-dependent admin controls
Public claim only
Copilot respects the identity model, permissions, sensitivity labels, retention and audit; the specific controls vary by subscription plan. MFA and Conditional Access are Entra settings, not Copilot-specific.
Ask: Require MFA and compliant devices, and demonstrate a disabled user loses Chat the same day.
At rest and in transit per Microsoft 365
Public claim only
EDP: encryption at rest and in transit for Copilot data under the same terms as Exchange and SharePoint. Customer Key coverage of Copilot interaction stores should be confirmed.
Ask: Does Customer Key cover Copilot Chat logs in Exchange?
GDPR, ISO 27018, DPA; HIPAA not for Bing
Public claim only
EDP lists GDPR, EU Data Boundary (with Bing/Anthropic footnotes), ISO/IEC 27018 and the DPA. HIPAA for properly configured implementations does not apply to web search queries. SOC reports via the compliance portal were not downloaded.
Ask: Provide SOC 2 / ISO 27001 / ISO 42001 scope covering Copilot Chat, excluding Bing.
Microsoft Customer Agreement / EA plus DPA; Bing MSA
Public claim only
Prompts and responses: Microsoft Product Terms and DPA (EDP). Web queries: Microsoft Services Agreement and Privacy Statement as independent controller, plus Product Terms commitments for Copilot-generated Bing queries. Liability cap and forum follow the firm's Microsoft agreement. Customer Copyright Commitment is cited for Copilot.
Ask: Confirm Copilot Chat is an Online Service on our DPA and that Bing remains carved out.
M365 geo plus Bing US and optional Anthropic
Public claim only
Chat processing is inside the Microsoft 365 boundary. Bing search storage/processing is United States per related Copilot Studio tables and is outside EU Data Boundary. Anthropic, if enabled, is excluded from EU Data Boundary and in-country processing. Non-EU tenants may have Copilot queries processed in US/EU/other regions.
Ask: Map every country for Chat inference, Exchange storage, Bing and Anthropic/OpenAI for our AU tenant.
Online Services incident process
Not confirmed
Incidents follow the Microsoft DPA for Online Services. This review did not extract a Copilot Chat-specific hour count. Bing as separate controller has a different notification path.
Ask: Within how many hours will we be notified of a Chat or Exchange Copilot-log incident, and who notifies for Bing?
Rename in progress; agents and model routes
Public claim only
Microsoft is renaming Microsoft 365 Copilot Chat to Microsoft Copilot Chat and says organisational privacy commitments are unchanged. Agents and Anthropic/OpenAI routes can be added by admin without a new seat licence.
Ask: Will you notify us before enabling Anthropic, OpenAI, web search or any agent that reads tenant files?
Exchange-held logs; Bing separate
Not confirmed
Copilot interactions in Exchange follow mailbox export/offboarding. Bing query data is not in that mailbox. No Chat-specific certified-deletion window was extracted.
Ask: How do we export Copilot Chat eDiscovery logs on tenant exit, and when are Bing copies gone?
File upload, Outlook, pay-as-you-go agents
Not confirmed
Four documented ways to bring organisational content into Chat: paste/upload/ContextIQ, Outlook Chat, and pay-as-you-go agents. Each agent's own terms apply. Web search is a connector to Bing.
Ask: Which upload, Outlook and agent paths are allowed, and how do we disable agents tenant-wide?
Bing grounding; separate controller
Public claim only
Web grounding is part of the Chat architecture when enabled. Queries are a few words from the prompt, no user/tenant IDs, not for ads or foundation-model training. Covered by the Services Agreement/Privacy Statement, not the DPA or BAA. Admins can manage public web access.
Ask: Is web search on for Copilot Chat, and can we turn it off tenant-wide?
Chat replies; agents and file generation extra
Not confirmed
Default Chat returns text. Documentation also covers generating files in Word, Excel and PowerPoint agents. Pay-as-you-go agents can take actions in other systems under their own terms. No firm-wide kill-switch is described beyond admin policy.
Ask: Which agents can write files or call APIs, and how do we freeze them immediately?
RAI checks; lawyer still reviews
Public claim only
Copilot runs Responsible AI checks before returning a response. There is no contractual requirement that a qualified lawyer approve Chat output. Web citations are not a substitute for checking Australian authorities.
Ask: Require human review before Chat output is used in advice or client documents.
