Copilot and privacy: is your company data protected?

Copilot is moving into Word, Outlook, Teams and Windows, right next to the organisation’s documents. Hence a legitimate question: what happens to the data it accesses and the data entrusted to it? Microsoft publishes specific commitments for work accounts. They are solid, but they rely on two conditions: using the right account, and having properly configured access rights.

Which Copilot are we talking about?

The name covers several services. Microsoft has renamed Microsoft 365 Copilot “Microsoft Copilot” and Microsoft 365 Copilot Chat “Microsoft Copilot Chat”, stating that this change does not alter security, compliance or privacy for organisations.¹ Alongside these, there is a Copilot app for individuals, used with a personal Microsoft account, whose privacy pages explicitly exclude work accounts.⁵

This distinction is the first thing to check: the safeguards described below only apply when signing in with a work account (Microsoft Entra ID).

Copilot’s enterprise data protection

Microsoft uses the term “enterprise data protection” for the set of commitments that apply to Copilot and Copilot Chat with a work account. According to Microsoft:

• interactions are covered by the Data Protection Addendum (DPA) and the Product Terms, with Microsoft acting as processor¹;
• prompts, responses and data accessed through Microsoft Graph are not used to train foundation models^1,2;
• Copilot respects the organisation’s identity model and permissions, inherits sensitivity labels and applies retention policies¹;
• the privacy commitments include the GDPR and the EU Data Boundary.^1,2

Microsoft also states that stored interactions (prompts and responses) are encrypted, handled under the same contractual commitments as other Microsoft 365 content, and that administrators can apply retention policies to them.² In Copilot Chat, a green shield displayed next to the “New chat” button shows that the protection applies.³

Access rights: what the tool does not fix for you

This is the most frequently underestimated point. Microsoft states that Copilot only surfaces organisational data that the user has at least view permission for, and stresses the importance of using Microsoft 365 permission models, such as those in SharePoint, so that the right people have access to the right content.²

In other words, Copilot does not create new access: it makes existing access much easier to exploit. A salary folder mistakenly shared “with the whole organisation” used to be hard to find. With an assistant that can search and summarise, it can turn up in an answer.

The same principle applies to other vendors: Google states, for example, that Gemini in Workspace follows existing permissions.⁸ Before a rollout, auditing sharing is therefore a security project in its own right, independent of the tool chosen. It ties in with the GDPR obligation to implement security measures appropriate to the risk (Article 32).⁶

Copilot and the GDPR: processing and data location

Under the GDPR, Microsoft positions itself as the organisation’s processor for Copilot, under its Data Protection Addendum.¹ It is this contract that meets the requirement of Article 28, under which a controller may only entrust data to a processor providing sufficient guarantees, with a contract governing the processing.⁶

On data location, Microsoft states that, for customers in the European Union, Copilot is an EU Data Boundary service: EU traffic stays within the boundary, although during periods of high demand, calls to the models may be routed to other regions for other customers.² Copilot has also been included in the data residency commitments of the Product Terms since 1 March 2024.²

Two further details complete the picture. Microsoft states that Copilot does not use Azure OpenAI abuse monitoring, which includes human review of content.² And optional user feedback may be used to improve Copilot, but not to train foundation models; administrators can manage it.²

Personal accounts: a different framework

An employee who signs in to Copilot with a personal Microsoft account leaves the framework described above. Microsoft’s page on Copilot for individuals states that it does not apply to work or school accounts.⁵ The former privacy FAQ, which concerns the previous app, stated that users signed in with a Microsoft account can control whether their activity is used for training, and that Microsoft does not train Copilot on the data of users signed in with an Entra ID work account.⁴

For the organisation, the issue is the same as with ChatGPT: a personal account falls outside its contract, its settings and its visibility, while the organisation remains responsible for the personal data entered into it.^6,7

Points to be aware of

• Web search. When web search is used, Copilot generates a query sent to the Bing service; Microsoft states that the EU Data Boundary does not apply to these queries.^1,2
• Agents and extensions. For a third-party agent, Microsoft advises checking its own privacy statement and terms of use.²
• Third-party models. Administrators can enable models from other providers; Microsoft states that models provided by Anthropic are currently excluded from the EU Data Boundary.^1,2
• Other assistants. Copilot’s protection only covers Copilot. Text pasted into other online services is subject to the terms of those services.

Before rolling out Copilot: the checklist

More broadly, the French CNIL recommends governing the use of generative AI through a policy that defines permitted and prohibited uses.⁷ For assistants used in the browser or in development tools, an on-device check can complete the setup: that is what Tacite-IA offers in Chrome and Edge and in coding assistants. It does not cover desktop apps, including Copilot in Windows.

Frequently asked questions

Sources

1. Enterprise data protection in Microsoft Copilot and Microsoft Copilot Chat. Microsoft Learn. Accessed on 5 October 2026.
2. Data, Privacy, and Security for Microsoft Copilot. Microsoft Learn, page dated 9 July 2026. Accessed on 5 October 2026.
3. Microsoft Copilot Chat Privacy and Protections. Microsoft Learn. Accessed on 5 October 2026.
4. Privacy FAQ for Microsoft Copilot. Microsoft Support. Accessed on 5 October 2026.
5. Microsoft Copilot for individuals: your data, privacy, and responsible AI. Microsoft Support. Accessed on 5 October 2026.
6. Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data (General Data Protection Regulation). EUR-Lex. Accessed on 5 October 2026.
7. Les questions-réponses de la CNIL sur l’utilisation d’un système d’IA générative. CNIL (French data protection authority), 18 July 2024. In French. Accessed on 5 October 2026.
8. Generative AI in Google Workspace Privacy Hub. Google Workspace. Accessed on 5 October 2026.

ChatGPT is a trademark of OpenAI, Copilot of Microsoft, Claude of Anthropic, Gemini of Google. Tacite-IA is not affiliated with any of these vendors. This article is for information only and does not constitute legal advice.