Product and intended use
Define the configuration, people, information and tasks being assessed.
IAM and CLM versus eSign-only
Public claim only
This profile covers Docusign IAM and CLM with Iris AI (including Lexion-derived review, extraction and Q&A). eSignature-only, Notary, IAM Starter/Standard self-serve, FedRAMP/GovRAMP and Professional Services have different schedules. Public MSA, DPA, Security Attachment and AI Attachment apply unless an Order Form says otherwise. Existing eSign/CLM customers are told nothing changes until they take an IAM plan in their region.
Ask: Confirm the Order Form SKUs (IAM versus CLM versus eSign), Australia region, whether Iris/Agents/MCP are in scope, and whether FedRAMP-style AI-training exclusion applies.
Five regions including Australia; Azure migration
Public claim only
Agreement Data is stored in one of five regions: US, Canada, Europe, Australia, Japan. eSign, IAM and CLM are all available in Australia; CLM is not in Canada or Japan. Region is chosen at provisioning (or by billing address for web signup) and cannot later be moved except by cloning via Admin API. Traffic is migrating from on-prem servers to Microsoft Azure without changing residency of Agreement Data. Checked 2026-10-10. Vendor page: “Docusign stores your Agreement Data in one of five geographically distinct data center regions (U.S., Canada, Europe, Australia, or Japan).” (https://www.docusign.com/trust/privacy/data-mgmt-privacy). Recorded as Australian region available.
Ask: Confirm our production, backup and Iris inference region is Australia, including Azure OpenAI and Vertex, before we send the first envelope.
Iris, CLM, Agents, MCP
Public claim only
IAM: create, commit and manage agreements. CLM: lifecycle automation, 100+ pre-trained extraction models, AI-assisted review and generative Q&A via Iris. Agents draft, review and orchestrate agreements. An MCP product page describes connecting Docusign to external AI tools. Lexion was acquired (31 May 2024) for document understanding inside IAM.
Ask: Which of Iris Q&A, AI-assisted review, Agents and MCP will be enabled on our AU tenancy, and which remain preview?
Australian region; NSW law for AU orders
Public claim only
AU data centre is listed for eSign, IAM and CLM. MSA 12.1(b): if the Order Form ship-to address is Australia, NSW law and non-exclusive NSW courts apply; claims within two years. Limited Transaction Data and login may still be processed outside the region. Gemini 'global endpoints' are listed for AI-assisted web form creation.
Ask: Will Iris inference, Azure OpenAI, Vertex Gemini and support access stay in Australia for our account, and is the Gemini global endpoint off?
Data, controls and requirements
Compare the actual configuration with firm, client and jurisdiction requirements, supported by evidence.
Agreement Data; optional AI training and MCP
Not confirmed
Docusign holds confidential agreements. AI training of Docusign models requires MSA consent and an account toggle. MCP and third-party integrations send data outside the region as those providers determine. Recipients outside the region still leave Agreement Data stored in the sender's region.
Ask: Confirm AI data controls are off for our AU accounts, MCP is disabled, and what region/subprocessor description we can give clients.
Hybrid in-house plus Azure OpenAI and Vertex Gemini
Public claim only
AI FAQs: hybrid proprietary/open-source models plus third-party LLMs via API — Microsoft Azure OpenAI Service and Google Vertex AI including Gemini. Subprocessor PDF (IAM/CLM): Azure OpenAI and Azure Document Intelligence follow the provisioning location including Australia; Gemini also listed for AU among others; Gemini global endpoints for AI-assisted web form creation. Third-party providers: no persistent storage; no training of those providers' models for other customers; anonymised data may customise Docusign-only models.
Ask: Which Azure OpenAI and Gemini models/regions process our AU IAM and CLM tenancy, and is the Gemini global endpoint excluded?
Published list dated 18 September 2026
Public claim only
Public list last updated 18 September 2026, split by data-centre location, purchased services and optional features. Group members provide follow-the-sun support. Azure and Equinix are example EU infrastructure subprocessors. IAM/CLM PDF rows name Azure AI Services and Google Vertex AI by provisioning location including Australia. SMS/ID-verification vendors apply only if those features are used.
Ask: Provide the AU-region subprocessor extract for IAM+CLM+Iris, with 30-day notice/objection, including Azure OpenAI and Vertex.
MSA consent plus account toggle; third-party LLMs not trained for others
Public claim only
Docusign will not use account data to improve its AI models unless the organisation agreed in the service agreement and the AI data controls setting is on (default on after consent; 30-day wait; turn off per account to withdraw). Previously anonymised data is retained because it cannot be unlinked. FedRAMP/GovRAMP do not share data for AI training. Third-party LLMs: customer data is not used to train those providers' models for other customers. MSA 4.3: de-identified Usage Data may be used to train and improve products.
Ask: Confirm in the Order Form that AI data controls start off for every AU account, that Lexion-era data is not in training corpora, and that Usage Data is not our Agreement Data.
Usage Data and bug-reporting FAQs
Public claim only
MSA 4.3: Usage Data, after de-identification, may be used for analytics, marketing and training/improving products, disclosed only in aggregate. Support FAQs cover reporting bugs and unexpected AI issues. In-product thumbs-up/down for Iris was not specified in the pages reviewed.
Ask: Is any in-product Iris feedback used to train models, and can we disable it without turning off the feature?
Region-bound Agreement Data; no public day count
Not confirmed
Residency page describes where Agreement Data and CLM documents/metadata sit, not how many days they are kept after a matter closes. Transaction Data may be hashed and copied across regions. AI-training wait is 30 days after consent, not a live-matter retention schedule.
Ask: Provide a numbered retention schedule for envelopes, CLM documents, Iris prompts/outputs, logs and backups in the AU region.
Admin controls; training anonymisation is irreversible
Public claim only
Customers manage Agreement Data in-product. Turning off AI data controls stops new ingestion; previously aggregated anonymised training data is retained because it cannot be linked back. No public post-termination deletion certificate or LLM-purge day count was found beyond third-party 'no persistent storage'.
Ask: On exit, what is deleted from the AU region, backups and Azure OpenAI/Vertex, within how many days, with what certificate?
Support cannot read eDocuments; follow-the-sun
Public claim only
eDocuments are encrypted as to Docusign and stored in the sending account's region; follow-the-sun staff may see limited Personal Information and Transaction Data, not document contents. MSA 11.2: required legal disclosure with prompt notice unless prohibited. Security Attachment: dedicated incident response team.
Ask: Is any break-glass access to Agreement Data logged to us, and will you notify us of legal process seeking our contracts?
Admin, SSO and AI data controls
Public claim only
Account administrators control users and the AI data controls setting. Security Attachment includes identity and access management. SSO is a standard enterprise control on the security programme; SCIM was not confirmed in this pass.
Ask: Do you support SAML/OIDC SSO-only, MFA enforcement and SCIM on our AU IAM/CLM account?
AES-256 application-level encryption
Public claim only
Product security page: application-level AES-256 encryption; ISO 27001-certified and SOC-audited geo-dispersed datacentres. AI FAQs: data encrypted in transit and at rest. eDocuments encrypted as to Docusign. CMK was not specified on the pages reviewed.
Ask: Confirm TLS 1.2+ and AES-256 for AU storage, backups and Azure OpenAI/Vertex paths, and whether CMK is available on IAM/CLM.
SOC, ISO 27001, PCI DSS via Security Attachment
Public claim only
Security Attachment: Docusign will make available ISO/IEC 27001, PCI DSS and SOC reports. Product security: ISO 27001-certified and SOC-audited datacentres. DPA s.9: SOC, ISO, NIST, PCI DSS or similar on request; customer audit no more than once per 12 months if reports are unsatisfactory. Reports were not downloaded.
Ask: Provide current SOC 2 Type II and ISO 27001 reports covering AU IAM/CLM and Iris/Azure OpenAI, including period and entities in scope.
Public MSA; NSW law for AU; 12-month cap; confidentiality carved out
Public claim only
Public MSA. AU ship-to: NSW law, non-exclusive NSW courts, two-year limitation. Aggregate liability capped at amounts paid for the Docusign Services in the 12 months before the first event, with carve-outs for third-party claims, confidentiality breach, death/bodily injury/property from negligence, gross negligence/willful misconduct, and unpaid fees. DPA and Security Attachment are incorporated. Customer must not use ML output to train other systems.
Ask: Will our Order Form lock AU residency, AI-training off, and keep the confidentiality carve-out for a data incident affecting Agreement Data?
Region at rest; Transaction Data and Gemini global endpoints
Public claim only
Agreement Data at rest stays in the provisioned region (Australia available). Limited Transaction Data may be hashed and copied across regions; login may redirect; support is global; third-party integrations follow the third party. BCRs and SCCs are referenced. Vertex Gemini global endpoints are listed for web-form creation. Azure OpenAI location follows provisioning, including Australia.
Ask: Name every country of Iris inference and support access for our AU account, including Gemini global endpoints, in writing.
Without undue delay; no public hour count
Public claim only
DPA s.6 and Security Attachment: notify Customer without undue delay (and within timeframes required by law) upon becoming aware of a Data Incident/Breach, unless prohibited. Customer decides whether to notify data subjects and regulators and should coordinate public statements with Docusign. No 72-hour figure is in the public DPA text reviewed.
Ask: Within how many hours of discovering a suspected incident affecting our AU Agreement Data will you notify us, and will you support an NDB assessment?
IAM rollout, Azure migration, subprocessor updates
Public claim only
IAM plans become available by region; existing eSign/CLM continue until the customer takes a new plan. eSignature traffic is migrating to Azure. Subprocessor list dated 18 September 2026. Agents and MCP are new surfaces. Region cannot be changed after provisioning except by clone.
Ask: Will you give 30-day notice before adding LLM providers, turning on MCP, or changing AU inference location?
In-product export; clone to another region; training data stays anonymised
Not confirmed
Customers can export Agreement Data in-product and clone accounts to a new region via Admin API. No public post-termination window or certified deletion of AU backups and LLM copies was found. Anonymised AI-training data from prior consent is retained.
Ask: How do we export CLM documents, playbooks, audit trails and Iris outputs on exit, and when are remaining AU and LLM copies deleted?
App Center, MCP, third-party services
Not confirmed
App Center integrations and APIs can send Agreement Data outside the region as the third party determines. MSA: Third-Party Services are the customer's contract unless the Order Form says otherwise. MCP connects Docusign to external AI tools. SMS/ID-verification subprocessors apply only if those features are used.
Ask: Which App Center and MCP connectors are on by default, what they send outbound, and how do we disable them without a ticket?
Iris over the agreement repository
Public claim only
Iris Q&A and Agreement Manager are described as operating on the customer's agreements. Open-web search as an Iris feature was not found. MCP would let an external assistant bring its own tools, including web search, unless blocked.
Ask: Confirm Iris does not call the open web on our contracts, and how MCP assistants are blocked from web search using our repository.
Agents and MCP orchestration
Not confirmed
Agents are marketed to draft, review and orchestrate agreements. MCP lets other applications reach Docusign workflows. Public MSA/AI FAQs do not describe a kill-switch or which agent steps can send envelopes without a named approver.
Ask: Which agent/MCP actions can send or change an agreement without a named approver, and how do we freeze them immediately?
No public clause requiring lawyer sign-off of Iris output
Not confirmed
Iris and Agents produce review comments, extractions and drafts. The MSA disclaims implied warranties and allocates professional use to the customer. No public clause requiring a qualified legal professional to approve Iris output before it is sent for signature was found.
Ask: Can we require named sign-off before an Iris redline or Agent-drafted envelope is sent, with an export of who approved which items?
