CollaborationMicrosoft 365 and the GDPR: agreement, role and data location.
Microsoft 365 is a collaboration tool. Most customers use it as a processor, it explains how to get its data processing agreement, and the data location depends on your account. Below: what to check and how to declare it.
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In short
- Category
- Collaboration
- Usual role
- Usually a processor
- Data location
- Set per account or project
- Agreement
- Obtained through the vendor
What does Microsoft 365 do with personal data?
Provide internal business email, calendar, document storage and collaboration. That is how Privacyboard describes a typical use of Microsoft 365, as a starting point you can edit.
The data usually involved: employee names, work email addresses, messages, documents and other content shared by the team.
Is Microsoft 365 a processor or a controller?
Most customers use Microsoft 365 as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for collaboration tools and it is what Privacyboard suggests.
As a processor, it needs a written agreement with you under Article 28, and you should know which subprocessors it uses. Confirm the role against your own agreement, because the way you use a tool can change it.
Where does Microsoft 365 store personal data?
Microsoft 365 does not have one fixed location for every customer. Set by the geography chosen for your tenant (for example Europe or United States).
How to find yours: Microsoft 365 admin center → Settings → Org settings → Organization profile → Data location shows where core data is stored.
Even when the main location is in the EU, ask whether subprocessors or support access involve a transfer outside the EEA, and record it if so.
Does Microsoft 365 have a data processing agreement?
Checked on 1 November 2026. Vendors change their pages, so check the date.
Microsoft 365 does not publish the full text of its data processing agreement on a public page. The reference page explains how a customer gets or signs it, usually from inside the account. Article 28 of the GDPR still requires a written contract, so get it and keep a copy.
What we noted when we opened the page: Licensing Documents page: lists the Products and Services DPA as downloadable files by year and language, the text itself is not on the page. Newest English edition listed: Nov 2026. Same agreement as Microsoft Azure.
A page that exists does not mean you are covered. Whether the agreement applies to you depends on your plan and on what you accepted, so record the decision yourself in your vendor list.
Open the Microsoft 365 reference pageHow to declare Microsoft 365
- 1
In your privacy policy
Name Microsoft 365 as a recipient, say what it is used for (provide internal business email, calendar, document storage and collaboration) and mention any transfer outside the EEA. Articles 13 and 14 ask you to tell people who receives their data.
- 2
In your vendor list
Add Microsoft 365 with its purpose, the data involved, its role, its region and a link to the agreement. Privacyboard prefills all of this, you confirm or correct it.
- 3
In your processing register
Link Microsoft 365 to the activities that use it, so each record shows its recipients. Article 30 asks the register to list the categories of recipients.
What to check before relying on Microsoft 365
- Decide which kinds of personal data may be pasted into the tool, and tell the team.
- Check the retention and deletion settings for messages and files.
- Review who has admin access and how guests are handled.
- Record the data region if the plan offers a choice.
Questions, answered.
Is Microsoft 365 GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how Microsoft 365 is configured and used, on the agreement you have with it and on your own practices. What can be checked is documented here: it explains how to get a data processing agreement, the usual role and the data location. Read the agreement itself before relying on it.
Does Microsoft 365 have a DPA?
Microsoft 365 does not publish the full text of its data processing agreement on a public page. The reference page explains how a customer gets or signs it, usually from inside the account. Article 28 of the GDPR still requires a written contract, so get it and keep a copy. The reference page is https://www.microsoft.com/licensing/docs/view/microsoft-products-and-services-data-protection-addendum-dpa.
Is Microsoft 365 a data processor?
Usually, yes. Most customers use Microsoft 365 as a processor that acts on their instructions. Check your own agreement and how you use the tool, because the role can differ.
Where does Microsoft 365 store data?
Microsoft 365 does not have one fixed location for every customer. Set by the geography chosen for your tenant (for example Europe or United States). How to find yours: Microsoft 365 admin center → Settings → Org settings → Organization profile → Data location shows where core data is stored.
Do I need to mention Microsoft 365 in my privacy policy?
Yes, if Microsoft 365 handles personal data for you. The GDPR asks you to tell people who receives their data (Articles 13 and 14). Name the vendor or its category, say what it is used for and mention any transfer outside the EEA.
How do I add Microsoft 365 to my vendor list?
In Privacyboard, pick Microsoft 365 from the catalog. The purpose, the data, the suggested role and a link to its agreement are prefilled, and you confirm each one. Creating a workspace is free.
Privacyboard is not affiliated with Microsoft 365. Names and logos belong to their owners and are used only to identify the tool. This page summarises public documents as checked on 1 November 2026; it is guidance, not legal advice, and it does not certify any vendor.