Microsoft · Microsoft Privacy Statement (Legacy) · View original document ↗

Enterprise and Organizational Data Processing

Medium severity Unique · 0 of 343 platforms
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This analysis describes what Microsoft'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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision establishes a contractual data processing relationship where Microsoft's privacy obligations are defined by the enterprise customer's agreement rather than Microsoft's public privacy statement. The enterprise customer assumes primary responsibility for privacy compliance and data governance under this arrangement.

Recent Activity

This document changed recently

Medium Apr 19, 2026

The updated policy establishes additional grounds on which Microsoft may retain personal data. While the prior version tied retention to specific user expectations and available deletion controls, the revised language authorizes retention for 'operating our business, meeting our contractual and legal obligations, improving and developing our products and services, protecting the safety and security of our systems and customers, and resolving disputes.' This expands the stated purposes beyond transaction fulfillment and legal compliance. The updated policy directs users to product-specific documentation for retention details rather than providing explicit deletion procedures and timelines in the privacy statement itself.

View change record →
Medium Apr 1, 2026

The updated policy now grounds data retention in five broad business purposes: operating the business, meeting contractual and legal obligations, improving and developing products and services, protecting system and customer safety, and resolving disputes. Previously, the policy articulated specific criteria for determining retention periods, including customer expectations for retention until manual deletion, availability of automated deletion controls, and data sensitivity. The revised language removes these granular criteria and instead requires users to consult individual product documentation to understand when their specific data will be deleted. This shifts the burden of finding retention timelines from the main policy statement to separate product-specific documents.

View change record →
Medium Mar 13, 2026

The updated Privacy Statement removes previously stated language about additional rights available to European Economic Area users, narrowing the policy's explicit protections in that region. Simultaneously, the revised terms now explicitly authorize Microsoft to contact users via auto-dialer and prerecorded voice for marketing purposes, provided the user has consented to receive marketing communications to the phone number supplied. This establishes Microsoft's contractual permission to initiate automated marketing calls using artificial intelligence-generated voice technology where user consent to marketing contact has been given.

View change record →

Clause Stability Stable

0
Changes
3
Months Monitored
Apr 9, 2026
First Seen
Apr 10, 2026
Last Seen
This clause type exists across 1153 other provisions on other platforms.

Consumer impact (what this means for users)

Users of enterprise-provisioned Microsoft products operate under their organization's privacy statement and data policies rather than Microsoft's standard privacy terms. Privacy inquiries and requests must be directed to the organization's administrator, who controls the terms governing personal data processing.

How other platforms handle this

MetaMask Medium

We may share your personal information with our affiliates, meaning entities that control, are controlled by, or are under common control with Consensys. We also share information with service providers who assist in operating our services, subject to confidentiality obligations.

Ledger Medium

At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.

Target Medium

RedCard. We share information with our financial partners to operate the Target RedCard program.

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▸ View Original Clause Language DOCUMENT RECORD
"
When Microsoft offers products to an enterprise or organization (your employer, school, or government entity), that enterprise customer controls and administers the Microsoft products and is the data controller for personal data associated with those products. Microsoft processes that data on behalf of the enterprise customer and, in such cases, Microsoft's privacy statement does not apply to the processing of your personal data. The enterprise customer's privacy statement applies. You should direct privacy inquiries to your organization's administrator.

— Excerpt from Microsoft's Microsoft Privacy Statement (Legacy)

Applicable regulations

BIPA
Illinois, USA
CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
DMA
European Union
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
UK GDPR
United Kingdom
Universal Opt-Out Mechanism Expansion 2026
US
VPPA
United States Federal

Provision details

Document information
Document
Microsoft Privacy Statement (Legacy)
Entity
Microsoft
Document last updated
March 5, 2026
Tracking information
First tracked
April 28, 2026
Last verified
May 12, 2026
Record ID
CA-P-002502
Document ID
CA-D-00001
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
9e697464d17b7148c787f07099c60e30370abb2b13a7f2a910f607e31ec13158
Analysis generated
April 28, 2026 08:11 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Microsoft
Document: Microsoft Privacy Statement (Legacy)
Record ID: CA-P-002502
Captured: 2026-04-28 08:11:57 UTC
SHA-256: 9e697464d17b7148…
URL: https://conductatlas.com/platform/microsoft/microsoft-privacy-statement-legacy/enterprise-and-organizational-data-processing/
Accessed: June 20, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Microsoft's Enterprise and Organizational Data Processing clause do?

This provision establishes a contractual data processing relationship where Microsoft's privacy obligations are defined by the enterprise customer's agreement rather than Microsoft's public privacy statement. The enterprise customer assumes primary responsibility for privacy compliance and data governance under this arrangement.

How does this clause affect you?

Users of enterprise-provisioned Microsoft products operate under their organization's privacy statement and data policies rather than Microsoft's standard privacy terms. Privacy inquiries and requests must be directed to the organization's administrator, who controls the terms governing personal data processing.

Is ConductAtlas affiliated with Microsoft?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Microsoft.