When your employer or school provides you with Microsoft products (like Microsoft 365 or Teams), your employer is in charge of your data, not Microsoft directly. This means your privacy rights in that context must be exercised through your employer, not Microsoft.
This analysis describes what Microsoft Azure's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
Employees and students using Microsoft products through their organization may not be able to exercise data rights (like deletion or access) directly with Microsoft and must instead go through their employer or institution, which may have different privacy practices.
Microsoft now discloses that it may contact you by phone for marketing using automated dialers and AI-generated voices if you have consented to marketing communications, which represents a new disclo…
Microsoft's privacy policy now provides a less detailed explanation of how long your data is retained. Previously, the policy included specific examples, such as how long deleted emails remain in you…
Microsoft's updated retention policy provides greater specificity about how long your data persists and under what conditions it is deleted. The policy now explicitly states that deleted items from O…
If you use Microsoft products provided by your employer or school, Microsoft states it acts only as a data processor, meaning your organization controls your data and you must direct any data access or deletion requests to your organization rather than to Microsoft.
How other platforms handle this
We collect and receive information as a data controller for our own purposes and as a data processor on behalf of our customers. When our customers use our products to process data about their end users and employees, we act as a data processor on their behalf. Our customers, as data controllers, de...
When Okta provides its products and services to its customers (e.g., organizations that use Okta to manage their workforce or Auth0 to manage their customer identity), Okta processes personal data on behalf of those customers as a data processor. In those cases, the customer is the data controller a...
When we provide the Service to our customers, we act as a data processor on behalf of those customers. Our customers are the data controllers, meaning that they determine the purposes and means of the processing of personal data that is submitted into the Service. If you are an end user of a custome...
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"When we provide enterprise online services to an organization that has licensed these services from Microsoft, we act as a data processor for the organization, which is the data controller. In these cases, the organization determines the personal data Microsoft collects on its behalf and how that data is used. The privacy practices of the organization govern your use of Microsoft's products and services.— Excerpt from Microsoft Azure's Microsoft Privacy
(1) REGULATORY LANDSCAPE: This provision directly engages GDPR Articles 4, 24, and 28, which define controller and processor responsibilities and require data processing agreements between them. Under GDPR, data subjects have rights against the controller; where Microsoft is processor, the employer organization bears primary responsibility for responding to data subject requests. The UK GDPR mirrors these requirements. (2) GOVERNANCE EXPOSURE: High. The controller-processor delineation has significant operational implications for enterprise HR, IT, and legal teams responsible for data subject access request fulfillment and for demonstrating GDPR accountability. Errors in this delineation or gaps in data processing agreements could result in regulatory exposure for both the enterprise customer and Microsoft. (3) JURISDICTION FLAGS: This distinction is most consequential in the EU/EEA and UK under GDPR, but also engages U.S. state privacy laws that recognize similar distinctions between controllers and processors (service providers under CCPA). (4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise procurement and legal teams must ensure a valid data processing agreement is in place with Microsoft that satisfies GDPR Article 28 requirements, specifies the scope of processing, and addresses sub-processor arrangements. Absence or inadequacy of such an agreement represents a direct compliance gap. (5) COMPLIANCE CONSIDERATIONS: Organizations should audit whether their Microsoft DPAs are current, whether they cover all Microsoft services in use (including new AI and Copilot products), and whether internal data subject request workflows correctly route employee requests to the organization rather than Microsoft.
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Employees and students using Microsoft products through their organization may not be able to exercise data rights (like deletion or access) directly with Microsoft and must instead go through their employer or institution, which may have different privacy practices.
If you use Microsoft products provided by your employer or school, Microsoft states it acts only as a data processor, meaning your organization controls your data and you must direct any data access or deletion requests to your organization rather than to Microsoft.
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