Microsoft Copilot Vendor Risk Assessment — Full Report

Recommended Actions

Steps to address findings for Microsoft Copilot

1. 1

   PRIORITY 1 — AI Training Commitment: Request and review the Microsoft Copilot Data Processing Addendum (DPA). Ask the Microsoft account team or privacy contact to confirm in writing whether customer data is used to train or improve AI models, and what the data retention period is for AI-processed inputs. Many enterprise customers can access this via the Microsoft Volume Licensing portal or the Microsoft Trust Center at https://www.microsoft.com/en-us/trust-center.

   DPA Template (GDPR Art. 28)
2. 2

   PRIORITY 2 — Subprocessor Disclosure: Request the current, Copilot-specific subprocessor list from Microsoft. Start by reviewing https://learn.microsoft.com/en-us/copilot/microsoft-365/microsoft-365-copilot-privacy and escalating to your Microsoft account manager if the Copilot subprocessor page remains unpopulated. Document this in your GDPR vendor inventory.

   GDPR Full TextGDPR Subprocessor Rules
3. 3

   PRIORITY 3 — SOC 2 Type II Report: Request Microsoft Copilot's current SOC 2 Type II report and bridge letter directly from your Microsoft account team or via the Microsoft Service Trust Portal at https://servicetrust.microsoft.com. Many Microsoft reports are available for download with a Microsoft account login.

   SOC 2 Overview (AICPA)
4. 4

   PRIORITY 4 — FedRAMP Scope Verification: Microsoft's FedRAMP authorization (independently verified at https://marketplace.fedramp.gov/products/F1209051525) covers Azure Commercial Cloud at High Impact Level. Confirm with your Microsoft account team whether Microsoft Copilot workloads are explicitly within the authorized FedRAMP boundary — not all products built on Azure inherit FedRAMP authorization automatically.

   FedRAMP Marketplace
5. 5

   PRIORITY 5 — Browser & System Integrity Controls: Tech community sources documented a March 2026 Microsoft Copilot update that hijacked default browser links, which may affect enterprise endpoint governance. Verify with your IT/endpoint team that current Copilot desktop deployments are configured in accordance with your organization's browser policy and that this behavior is controlled through Group Policy or Intune settings.

6. 6

   PRIORITY 6 — Screen Capture Privacy Controls: Community discussions noted Copilot's screen-reading capability in Edge. Review your organization's Microsoft Copilot policy settings and confirm that screen capture features are governed by your acceptable use policy — particularly for employees working with regulated data. Enterprise controls are available via Microsoft 365 admin center.

• The Web archive service archive indicates copilot.microsoft.com as a subdomain first appeared in early 2026, despite microsoft.com being a 34-year-old domain. The subdomain's short web history limits historical context for this specific product domain; findings are based on current-state evidence only.
• The subprocessor page at copilot.microsoft.com returned no extractable content at the time of assessment. It is possible the page was unpopulated at the time of scanning; buyers should verify its current state directly.
• External cyber risk scoring for this vendor was not available during this assessment; infrastructure findings are based on port scanning and CVE analysis only.
• SOC 2 Type II compliance status could not be independently confirmed — no public registry exists for SOC 2 attestations, and no claim was identified on publicly accessible Microsoft Copilot trust pages. This is a data availability limitation, not a confirmed absence of certification.
• AI training data policy analysis was based on publicly accessible documentation. Contractual DPA terms, enterprise-specific commitments, or unpublished policy language were not within scope of this assessment.
• The HTTP Observatory scan assessed copilot.microsoft.com as the scan target; results reflect the consumer-facing application domain and may not represent the full security header configuration of the underlying enterprise API infrastructure.
• Firmographic data (headcount, industry classification, company type) was not available for the subdomain copilot.microsoft.com via external sources; Microsoft Corporation's broader company profile was not independently surfaced in this assessment.
• Soc *2 coverage was limited for this investigation. This does not confirm any deficiency — direct verification with the vendor is recommended.