Product and intended use
Define the configuration, people, information and tasks being assessed.
Updated personal app versus older app and M365 home
Not confirmed
This profile covers the updated Microsoft Copilot app available from 18 August 2026 when signed in with a personal Microsoft account. The older-app Privacy FAQ still permits conversation activity for model training unless opted out. Copilot inside home Microsoft 365 apps and Entra work/school sign-in have separate documentation. Cowork multi-step tasks and model choice vary by subscription.
Ask: Confirm we are on the post-18 August 2026 app, signed in with a personal account only, and that no work files are uploaded.
Consumer cloud; region not published
Not confirmed
The individual-app privacy pages do not name a storage or inference region. Do not carry over Microsoft 365 Advanced Data Residency or EU Data Boundary commitments from the organisational Copilot profile.
Ask: Where are personal Copilot chats, files and memories stored and inferred for an Australian user?
Chat, memory, Cowork, web search, ads
Public claim only
Chat with history; optional saved memories; web search (toggle); shared experiences with Bing/Edge/MSN; advertising if there is no Microsoft 365 subscription; Cowork for multi-step tasks; user can choose among leading models. Feature set varies by subscription.
Ask: Which of memory, web search, shared experiences, Cowork and model choice will be on for our testers?
US consumer terms; no AU residency commitment
Public claim only
Use is under the Microsoft Services Agreement and Copilot Terms of Use, plus the Microsoft Privacy Statement. Those are consumer contracts, not the organisational DPA. Processing location for personal Copilot is unpublished. Older-app FAQ excludes some countries from training; Australia is not on that exclusion list.
Ask: If a lawyer uses personal Copilot on client facts, which country holds the chat and does APP 8 consent cover Bing and ads?
Data, controls and requirements
Compare the actual configuration with firm, client and jurisdiction requirements, supported by evidence.
Do not put client content in a personal account
Not confirmed
A personal Microsoft account is not a firm tenancy. Uploading client documents or pasting matter facts creates a disclosure to Microsoft as a consumer-service controller, plus optional Bing, ads and (older app) training. No client-disclosure template exists because this is not an authorised firm tool.
Ask: Prohibit client content in personal Copilot and say so in the acceptable-use policy.
Microsoft-hosted; user may choose among models
Public claim only
Overview: users can choose between leading AI models depending on subscription. Providers and regions are not named on the individual privacy pages. Do not assume Azure OpenAI organisational terms.
Ask: Which models does the updated personal app actually call, and in which country?
No public consumer subprocessor list
Not confirmed
No dated subprocessor schedule is linked from the individual Copilot privacy articles. Bing search and advertising partners may process conversation-derived content depending on settings.
Ask: If personal Copilot is ever allowed, demand the consumer subprocessor list including Bing and ads.
Updated app: no foundation-model training; older app: opt-out
Public claim only
Updated app activity-history page: prompts, responses and file contents are not used to train foundation models. Older-app FAQ: conversation activity, including uploaded files, is used for generative-AI training unless the user opts out or is in an excluded country (Australia is not listed). Do not mix the two statements.
Ask: Confirm every user is on the updated app; if anyone is on the older app, require training opt-out before any use.
Optional feedback; not for foundation-model training on the new app
Public claim only
Updated app: optional customer feedback may improve Copilot like other Microsoft 365 services but is not used to train foundation models. The linked feedback process can request additional prompts, responses, content samples and logs. Older app treats conversation activity itself as training data unless opted out.
Ask: Disable feedback and do not submit chats that contain work content.
Chat history plus separate memories
Public claim only
Updated app retains chat history. Saved memories persist until deleted; turning the Saved memories toggle off does not delete existing memories. Older-app FAQ: uploaded files kept no longer than 18 months. No numbered live-chat day count is on the updated activity-history page.
Ask: What is the default retention for chats, memories, logs and backups on the updated app?
Per-chat delete; dashboard export; memories separate
Public claim only
Users can delete individual chats and export or delete activity history via the privacy dashboard. Memories must be deleted under Personalization → Manage; off does not equal delete. Previously used training data on the older app cannot be unlearned from a model.
Ask: After deleting chats and memories, what remains in backups and advertising/Bing shared-experience stores?
Consumer controller; no Lockbox
Not confirmed
Personal Copilot is not Customer Lockbox territory. Terms allow Microsoft to block or remove prompts that violate the Terms. Support access to consumer chats is not described in the individual privacy articles.
Ask: Assume Microsoft can access consumer chats under the Privacy Statement; do not put client data there.
Personal Microsoft account only
Public claim only
Sign-in is a personal Microsoft account. There is no Entra Conditional Access, sensitivity labels or admin MFA enforcement for this plan. Anyone with the password can see chat history and memories.
Ask: If the firm allows personal Copilot on a device, require a unique personal account never used for work mail.
Not specified on the individual privacy pages
Not confirmed
Older FAQ says uploaded files are stored securely. TLS/AES and customer-managed keys are not stated on the updated individual privacy articles. Do not infer Microsoft 365 encryption commitments.
Ask: If this product were ever approved, demand encryption-in-transit/at-rest evidence for chats and files.
No SOC/ISO claim on the personal-app pages
Not confirmed
The individual Copilot privacy articles do not cite SOC 2 or ISO 27001 for the consumer app. Organisational Copilot certifications do not automatically cover personal accounts.
Ask: Do not treat Microsoft 365 Copilot ISO/SOC reports as covering personal Copilot.
MSA + Copilot Terms of Use; user indemnifies Microsoft
Public claim only
Microsoft Services Agreement and Copilot Terms of Use (personal). Terms do not apply to Entra accounts. User agrees to indemnify Microsoft for use, sharing or publication of prompts, responses or creations. Responses may not be unique. No organisational liability cap or DPA.
Ask: Confirm personal Copilot is outside our Microsoft Customer Agreement and must not be used for firm work.
Unpublished destinations; Bing and ads
Not confirmed
No region map. Web search sends queries for public web grounding. Shared experiences and advertising can use conversation content, history and memories. Older-app training may use conversation activity globally except listed excluded countries.
Ask: If use is ever permitted, name every country of storage, inference, Bing and advertising.
Consumer Privacy Statement only
Not confirmed
No 72-hour organisational notification. Breach handling follows the Microsoft Privacy Statement for consumer services, not the Online Services DPA.
Ask: Do not rely on personal Copilot for notifiable client data.
App rewrite 18 August 2026; terms changeable
Public claim only
The 18 August 2026 app change switched training defaults. Consumer terms can change under the MSA. Remaining on the older app keeps the opt-out training model.
Ask: How will we detect who is still on the older app after 18 August 2026?
Dashboard delete; memories extra step
Public claim only
Privacy dashboard can export or delete Copilot activity history. Memories need a separate delete-all. Closing the Microsoft account is a further step not detailed on these pages.
Ask: What remains after dashboard deletion and account closure, including ads and Bing personalisation stores?
Edge import; shared Bing/MSN
Not confirmed
Controls include importing browser data from Edge and One shared experience with Bing/Edge/MSN. Each is a disclosure path from Copilot chats into other Microsoft consumer products.
Ask: Keep Edge import and shared experiences off on any device that might see work content.
Web search on by default; user toggle
Public claim only
Copilot can search the web for current public information. Users can turn Web search off under Personalization. Queries are not described as DPA-covered.
Ask: If the app is used at all, require web search off unless the task is purely public-web research with no client facts.
Cowork multi-step tasks
Not confirmed
Overview describes Cowork helping with bigger multi-step tasks and completed to-dos. Terms allow Copilot to offer responses for things the user asked it to remember. No firm approval gate exists.
Ask: Disable Cowork/agentic actions on personal Copilot if the firm allows the app on a managed device.
User must review before publishing
Public claim only
Terms: user is responsible for use of prompts and responses; indemnifies Microsoft. No in-product lawyer sign-off. Unsuitable as a supervised legal workflow.
Ask: Keep personal Copilot out of any workflow that produces client-facing work product.
