Microsoft liable for DPF onward transfers by agents

The updated privacy statement removes the previous detailed list of third-party sources from which Microsoft obtains personal data, including data brokers, public social media posts, location service providers, co-branded partners, and developers. Under the revised language, Microsoft describes obtaining data from 'Microsoft affiliates, subsidiaries, and third parties' without specifying the categories or types of third parties as explicitly as before. The company states it has reorganized the document for greater clarity and accessibility, but the operational effect is that users receive less specific disclosure about where their data originates from outside Microsoft.

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.

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.