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Are Copilot prompts in your audit log?
Enable auditing of Copilot interactions and define retention aligned with legal and regulatory needs.
Reviewed by Datalegale · last source check 24 August 2026. About 3 min read. This is not legal advice.
What to do next
Turn auditing on, set retention to match legal need rather than the product default, and test a retrieval before the first subject access request.
Prompts and responses are stored in ways that can be in-scope for eDiscovery and subject access requests. Default retention is not automatically your legal retention. Configure auditing, document how long you keep Copilot interactions, and test that you can retrieve them.
What to enable
Turn on auditing of Copilot interactions and related activities. Confirm who can read those logs. Decide whether you need to keep prompts, responses, or both, for which period, and for which legal hold scenarios.
If you cannot produce a Copilot thread when a data subject or a court asks, the rest of the DPIA’s “we have audit” sentence is not true.
How to check it
Use Microsoft Purview audit and retention policies that list Copilot workloads. Run a test: a pilot user asks a distinctive question, then an admin confirms the activity is visible and retained as designed. Put the test date in the governance file.
Subject access and deletion
If a staff member or customer asks what Copilot processed about them, you need a retrieval path. If they ask for deletion, you need to know what you can actually delete versus what is in a legal hold. Those answers should exist before the first request, not during it.
Align Copilot retention with the function: HR prompts are not the same as a public-web research chat. A single default for the whole tenant is simpler to run and harder to defend if you hold regulated data for too long — or delete it too soon.
Is Copilot GDPR compliant? Flex Routing FAQ
Are prompts personal data?
They often are, or they can be. People paste names, case IDs and email threads. Treat prompts and responses as potentially in-scope for access, deletion and retention rules.
Is the default retention our legal retention?
No. Product defaults are not your record schedule. Align Copilot retention with how you already treat email and files for that function.
Related guides
- What to check before assigning Copilot licences
A safe European rollout combines technical configuration, accountability documentation and organisational measures. The sequence matters.
- Does the EU AI Act replace GDPR for Copilot?
Most organisations using Copilot as a deployer have lighter AI Act duties than providers. GDPR obligations remain fully applicable.
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Is Microsoft’s Copilot DPIA Template Enough? · 10 questions
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