“Is Microsoft Copilot GDPR-compliant?” is what the data protection officer asks the morning after the Copilot icon shows up in Outlook, Teams and Edge for everyone in the company. Half the team has already tried it, some with their work account, some with a personal one. This article answers the question plainly, as of October 2026: which Copilot is which, what Microsoft commits to, where the gaps are, what it costs and what a compliant setup needs. Many companies can use Copilot compliantly with the right setup. This is not legal advice - confirm the details with your own data protection officer.
Key takeaways
The account decides: with a work account (Entra ID), Copilot and Copilot Chat run under Microsoft’s Data Protection Addendum, with no training on your data and the EU Data Boundary for EU customers. The consumer Copilot with a personal account does not14.
Three gaps to close: web search queries to Bing sit outside the DPA and the EU Data Boundary, Anthropic models are currently excluded from the EU Data Boundary, and Copilot sees everything a user may see, including overshared files123.
Your duties stay with you: a lawful basis (Art. 6 and 9 GDPR), a record of processing (Art. 30), a DPIA where the risk is high (Art. 35) and AI literacy under Art. 4 of the EU AI Act910.
Is Microsoft Copilot GDPR-compliant?
Microsoft Copilot is not GDPR-compliant or non-compliant on its own: used with a work account under Microsoft’s Data Protection Addendum, with web search and permissions under control and your own documentation in place, it can be used in a GDPR-compliant way. Microsoft states that Copilot meets its GDPR and EU Data Boundary commitments to Microsoft 365 business customers and does not train foundation models on prompts and responses2. What remains is your part: the right account, the right settings and the paperwork.
Note on names
In 2026 Microsoft renamed Microsoft 365 Copilot to Microsoft Copilot and Microsoft 365 Copilot Chat to Microsoft Copilot Chat; licences and price lists still use the old names2. For data protection, what counts is the account a person signs in with, not the name on the icon.
The European way inside Outlook and Teams: Superkind
If your team lives in Outlook and Teams, you can add an AI employee without leaving Microsoft 365. Superkind is the AI employee for your team: you write to Superkind in Outlook or any email, Microsoft Teams, Slack or the Superkind web app like you would to a colleague, and it does the task in your programs through 1,500+ integrations such as SharePoint, Excel, HubSpot and DATEV. Superkind is hosted and processed in Europe, GDPR compliant, aligned with the EU AI Act and never trains models on your data. It works with AI models from OpenAI, Anthropic, Mistral and Google, all processed in Europe, and the data processing agreement comes through the Trust Center. The difference to Copilot is the job: Copilot helps each person write and summarise, Superkind takes over whole tasks.
- 1
You write the task
In Outlook, Teams, Slack or the web app, in plain words: “Answer Ms Berger’s question about her order and log the call in HubSpot.”
- 2
Superkind does it in your systems
It reads the email, looks up the customer in HubSpot, uses your company knowledge (delivery times, tone, past cases) and follows your rules, such as “Credit notes over EUR 200 need sign-off from the team lead”.
- 3
Superkind asks before anything goes out
You get the draft reply and the CRM entry with Approve or Reject. Nothing is sent or changed without your OK, and a colleague can approve in Teams or Slack.
- 4
Next time it runs as a routine
What you explain once keeps running, for example “Every order question - draft the reply, log it, ask me”. Every task adds to your Company Brain.
Answer Ms Berger’s question about order 4012, log the call note in HubSpot and send me the reply for approval before it goes out.
Send Superkind your first task in Outlook or Teams
Start for free. Hosted in Europe, no training on your data, approval before anything goes out.

How Copilot and the GDPR fit together
The GDPR does not ban Copilot. Six parts decide whether your use is compliant.
- The account and the contract - with a work account (Entra ID), Copilot and Copilot Chat are covered by the Microsoft Products and Services Data Protection Addendum (DPA) and the Product Terms, with Microsoft acting as processor under Art. 28 GDPR. Microsoft calls this enterprise data protection. The consumer Copilot with a personal Microsoft account is not covered14.
- No training on your data - prompts, responses and data accessed through Microsoft Graph are not used to train foundation models. On the consumer Copilot, Microsoft may use conversations for training unless the user opts out24.
- Where the data is processed - for EU customers, Copilot is an EU Data Boundary service: EU traffic to the language model stays within the boundary. Anthropic models, which admins can switch on in Copilot, are currently excluded from the EU Data Boundary12.
- Web search via Bing - when web search is on, Copilot sends short search queries to Bing without user and tenant identifiers. For these Microsoft is an independent controller; the DPA and the EU Data Boundary do not apply. Admins can turn web search off with the “Allow web search in Copilot” policy3.
- Permissions and oversharing - Copilot only surfaces data a user has at least view permission for. That also means every overshared SharePoint site or Teams channel becomes easier to find, which is why Microsoft points to your SharePoint permission models2.
- Your own paperwork - a lawful basis under Art. 6 (and Art. 9 for health or other special categories), an entry in your record of processing (Art. 30) and a data protection impact assessment (Art. 35) where the use is likely to be high risk. Under the EU AI Act, Art. 4 requires AI literacy for staff since February 2025, and Art. 50 adds transparency duties from 2 August 2026, such as labelling AI-generated text published to inform the public unless a person reviewed it910.
Where the German authorities stand
In 2022 the German data protection conference (DSK) found that controllers could not prove compliant use of Microsoft 365 on the basis of Microsoft’s DPA of September 2022. In November 2025 the Hessian authority (HBDI) concluded that, on those seven points, compliant operation is now possible, citing changed law and Microsoft’s adjustments, and expecting Microsoft and controllers to work together8. The report covers Microsoft 365 in general; your Copilot setup still needs its own check.
The three Copilots and the GDPR compared
As of October 2026. Where each version stands on the points that decide GDPR fit, with Superkind for comparison, based on the vendors’ own statements1234. Not a compliance sign-off.
| Version | Works with | Training on your data | Hosting / Data protection | DPA / AVV |
|---|---|---|---|---|
| Superkind (for comparison) | Outlook, Teams, Slack, web app; does tasks in 1,500+ integrations (SharePoint, Excel, HubSpot, DATEV ...) with approval | Never | Hosted and processed in Europe | Yes, via the Trust Center |
| Copilot (consumer), personal Microsoft account | Web and what the user pastes in | Possible unless the user opts out4 | Consumer terms, not covered by the business DPA | No |
| Microsoft Copilot Chat (formerly Microsoft 365 Copilot Chat), work account | Web, uploaded files, the open page in Edge; since the 2026 suite update also inbox and calendar awareness in many plans7 | No1 | Enterprise data protection, EU Data Boundary; web queries to Bing outside it13 | Yes, Microsoft DPA1 |
| Microsoft Copilot (formerly Microsoft 365 Copilot), paid licence | Emails, chats, meetings, files via Microsoft Graph, within each user’s permissions | No2 | EU Data Boundary service; Bing queries and Anthropic models outside it12 | Yes, Microsoft DPA1 |
In short: the consumer Copilot is the wrong place for customer or employee data; with a work account you get the contract and the EU Data Boundary, and the open points are web search, optional models and permissions. For a side-by-side with OpenAI’s offer, see Copilot vs ChatGPT Enterprise, and for the ChatGPT side of this question, Is ChatGPT GDPR-compliant?
Examples: Copilot and the GDPR in practice
Five realistic situations and what each needs to stay compliant.
1. Superkind handles customer requests in Outlook and Teams
Daniel forwards a customer email in Outlook to Superkind. Superkind looks up the order, drafts the reply, logs the call note in HubSpot and asks Daniel for approval before anything goes out. The data is processed in Europe, with no training on it and the DPA through the Trust Center. It connects through 1,500+ integrations such as SharePoint, Excel, DATEV and Zendesk. See email inbox triage for how this runs day to day.
2. Copilot Chat for drafting, with a work account
The team uses the free Copilot Chat to draft job ads. Signed in with Entra ID, prompts and responses fall under the DPA1. The open point is web search: names of customers or employees in a prompt can end up in a Bing query outside the DPA. Turn web search off or set a clear rule.
3. The paid Copilot finds the salary list
An assistant asks Copilot to “summarise everything about the bonus round” and gets a spreadsheet from a SharePoint site opened to the whole company years ago. Copilot only shows what the user may see2, but the old oversharing is now one question away. Review HR, finance and management sites before the rollout.
4. A colleague uses Copilot with a personal account
Someone pastes a customer complaint into Copilot while signed in with a private Microsoft account. That chat is not covered by your DPA, and Microsoft may use it for training unless the user opted out4. Make the rule explicit: company data only with the work account.
5. HR summaries with health data
An HR lead wants Copilot to summarise sick notes and return-to-work talks. Health data is a special category under Art. 9 GDPR; here a DPIA under Art. 35 is likely due9. For how to run one, see DPIA for AI agents.
What a compliant Copilot setup needs (and what it costs)
Short, but none of it happens by itself.
- Work accounts only - company data only with the Entra ID work account, where the DPA applies1.
- A decision on web search - leave it on with a rule, or turn it off with the “Allow web search in Copilot” policy3.
- A decision on optional models - keep Anthropic models off, or enable them for named groups and record that they sit outside the EU Data Boundary1.
- Clean permissions - review SharePoint and Teams sites with broad access, use sensitivity labels, and start with a pilot group2.
- Record of processing and DPIA - add Copilot to your record (Art. 30) and run a DPIA (Art. 35) where the risk is high9.
- AI literacy and transparency - train staff and set rules under Art. 4 EU AI Act; from 2 August 2026, Art. 50 adds transparency duties for some AI-generated content10.
What Copilot costs
As of October 2026. Microsoft list prices for Germany, per user per month, excl. VAT, on top of a Microsoft 365 licence.
| Product | Price | Note |
|---|---|---|
| Superkind (for comparison) | Free start, Business from EUR 50 per month | For the whole company, unlimited users, no price per seat |
| Microsoft Copilot Chat | No extra cost | Included with eligible Microsoft 365 plans5 |
| Microsoft 365 Copilot Business (add-on) | EUR 18.20 annual (EUR 15.60 promo), EUR 21.84 monthly | Promo for the first year, 1 July to 31 December 2026, existing business customers5 |
| Business Standard + Copilot Business | EUR 20.36 annual | Bundle; EUR 24.43 with monthly billing5 |
| Business Premium + Copilot Business | EUR 27.73 annual | Bundle; EUR 33.28 with monthly billing5 |
| Microsoft 365 Copilot (enterprise) | EUR 26.00 annual | Requires a qualifying Microsoft 365 plan6 |
On top of the licences, Microsoft bills some advanced experiences such as agents by usage through Copilot Credits5. The Microsoft 365 suites themselves got more expensive on 1 July 2026: in Microsoft’s USD list, Business Basic went from $6 to $7, Business Standard from $12.50 to $14 and Microsoft 365 E3 from $36 to $39 per user per month, from the next renewal for existing customers; standalone Copilot SKUs were not part of that change7. Ten Copilot Business seats on an annual plan come to EUR 182 per month before VAT at list price.
Data protection and EU hosting
Superkind and your data
- Hosted and processed in Europe
- GDPR compliant
- Aligned with the EU AI Act (Regulation (EU) 2024/1689)
- No model training on your data
- Data processing agreement (DPA) through the Trust Center
For a customer email in Outlook, a contact in HubSpot or a file in SharePoint, the personal data Superkind works with is processed in Europe from the first task, with approval before anything leaves the team.
What Superkind costs
As of October 2026. Prices excl. VAT, for the whole company with unlimited users.
- Free - EUR 0 with a one-off up to EUR 150 in credits to start. No credit card, no sales call, every feature and connection.
- Business - from EUR 50 per month for 25,000 credits. EUR 100 for 50,000 credits is the popular step, then EUR 200 and EUR 500. No price per seat, unused credits carry over one month, custom apps included, cancel monthly.
- Enterprise - custom price for your volume, dedicated support with SLA, SSO/SCIM and audit log, a DPA and help with the security review, payment by invoice.
- What credits buy - a question uses 10-50 credits, a task 50-500 credits and a run of your own agent 1,000-5,000 credits. EUR 100 covers up to 1,000 tasks or 5,000 questions.
How to start
Start with one real task and get Copilot in order in the same week. Three steps:
Your 3-step plan
- Test an AI employee on one real task - start Superkind for free at app.superkind.ai with up to EUR 150 in credits, send one real task in Outlook or Teams, and compare. Many teams use both: Copilot for writing, Superkind for tasks across several systems. More options: the 10 best Copilot alternatives.
- Write the rule and check the tenant - company data only with work accounts; decide on web search and optional models in the Microsoft 365 admin center; add Copilot to your record of processing. That also starts your AI literacy duty under Art. 4 EU AI Act10.
- Clean up permissions before the rollout - review the SharePoint and Teams sites with the widest access and start the paid Copilot with a pilot group.
From the first task to your own app
With Superkind, the data stays in Europe from the first task to the app you build later. Four stages, on the customer-request example from above:
- 1
Ready in minutes
Sign up for free, forward the first customer email in Outlook and watch Superkind draft the reply and log it in HubSpot.
- 2
Tasks become routines
What you explain once keeps running as a routine, for example every order question answered and logged. Before anything goes out, Superkind asks for approval.
- 3
Learns from day one
Every task makes Superkind smarter. Customers, prices and processes end up in your Company Brain, and that knowledge is never lost.
- 4
Your own app, without starting over
When it gets more complex, you build custom solutions, apps and integrations on top of what Superkind already knows, for example your own customer service app: your Super App. Built yourself or together with us. It all belongs to you.
Conclusion
Microsoft Copilot can be used in a GDPR-compliant way: with work accounts it runs under Microsoft’s DPA, without training on your data and inside the EU Data Boundary for EU customers, and a German authority now considers compliant Microsoft 365 operation possible. The work is in the details: Bing web search and optional Anthropic models sit outside the boundary, Copilot sees every overshared file, and the paperwork stays with you. For an AI employee that does whole tasks in Outlook and Teams, hosted in Europe with approval before anything goes out, Superkind connects to SharePoint, Excel, HubSpot, DATEV and 1,500+ integrations from EUR 50 per month for unlimited users (as of October 2026). Check your tenant settings this week, then send Superkind one real task and compare.
Frequently Asked Questions
Microsoft Copilot can be used in a GDPR-compliant way when your staff sign in with their work account (Microsoft Entra ID). Then prompts and responses fall under the Microsoft Products and Services Data Protection Addendum, Microsoft acts as processor, the data is not used to train foundation models, and for EU customers Copilot is an EU Data Boundary service. Web search queries sent to Bing are the exception: the DPA and the EU Data Boundary do not apply to them. You still need a lawful basis, clean permissions, a record of processing and, where the risk is high, a DPIA. As of October 2026, not legal advice.
The consumer Copilot with a personal Microsoft account is a private service: it is not covered by the business DPA, and Microsoft may use conversations for model training unless you opt out. Copilot Chat signed in with a work account (Entra ID) is included with eligible Microsoft 365 plans and has enterprise data protection, but it works mainly with the web, the files you give it and, in many plans since 2026, your inbox and calendar. The paid Microsoft 365 Copilot (now renamed Microsoft Copilot) also reads your emails, chats and files through Microsoft Graph, within the permissions of each user.
Not with work accounts. Microsoft states that prompts, responses and data accessed through Microsoft Graph are not used to train foundation models, for both Copilot and Copilot Chat. For the consumer Copilot with a personal Microsoft account, Microsoft may use conversations for training unless the user opts out, which is one reason to keep company data out of personal accounts.
For EU customers, Microsoft lists Copilot as an EU Data Boundary service: EU traffic for the language model stays within the EU Data Boundary. Two things sit outside it: web search queries sent to Bing, and Anthropic models, which Microsoft currently excludes from the EU Data Boundary and which admins decide whether to switch on. If you need all processing inside the boundary, turn off web search with the "Allow web search in Copilot" policy and keep Anthropic models off.
Copilot only shows data the user has at least view permission for, but that includes everything that was overshared over the years: a salary list in a team site open to everyone, or an old HR folder with broad access. Copilot makes those mistakes easier to find. Before the rollout, review SharePoint and Teams permissions, apply sensitivity labels to confidential files, and start with a pilot group.
Your team writes to Superkind in Outlook or any email, Microsoft Teams, Slack or the web app, and Superkind does the task in your programs through 1,500+ integrations such as SharePoint, Excel, DATEV, HubSpot and Personio, with AI models from OpenAI, Anthropic, Mistral and Google processed in Europe. It asks for approval before anything goes out, follows your rules and keeps the knowledge in your Company Brain. It is hosted and processed in Europe, never trains on your data, and the DPA comes through the Trust Center.
As of October 2026, Microsoft lists Copilot Chat at no extra cost with eligible Microsoft 365 plans, Microsoft 365 Copilot Business at EUR 18.20 per user per month on an annual plan (first-year promotion EUR 15.60 until 31 December 2026) and Microsoft 365 Copilot for enterprise at EUR 26.00 per user per month, all excl. VAT and on top of a Microsoft 365 licence. Superkind starts free with a one-off up to EUR 150 in credits; Business starts from EUR 50 per month for the whole company with unlimited users, no price per seat.
Sources
- Microsoft Learn - Enterprise data protection in Microsoft Copilot and Copilot Chat (DPA, no training, EU Data Boundary exclusions)
- Microsoft Learn - Data, privacy and security for Microsoft Copilot (permissions, EU Data Boundary, renaming)
- Microsoft Learn - Data, privacy and security for web search in Copilot and Copilot Chat (Bing, admin policy)
- Microsoft Support - Privacy FAQ for consumer Microsoft Copilot (model training, opt-out)
- Microsoft Germany - Microsoft 365 Copilot Business pricing (EUR, excl. VAT)
- Microsoft Germany - Microsoft 365 Copilot for enterprise pricing (EUR, excl. VAT)
- Microsoft Licensing - 2026 Microsoft 365 packaging and pricing updates (effective 1 July 2026)
- HBDI (Hessian data protection authority) - Report on Microsoft 365, November 2025
- EUR-Lex - Regulation (EU) 2016/679 (GDPR), Art. 6, 9, 28, 30, 35
- EUR-Lex - Regulation (EU) 2024/1689 (EU AI Act), Art. 4 and Art. 50
Send Superkind your first task.
Start for free in Outlook, Teams or Slack, hosted in Europe. Or see in 30 minutes how it runs in your Microsoft 365 setup.

