Microsoft
MicrosoftThank you, Suhel_Parekh. This article is helpful, but there is a real tension between Microsoft’s stated protections and the absence of an explicit HIPAA compliance claim for Copilot Chat. Even with the “four layers of protection,” Microsoft does not certify Copilot Chat as HIPAA compliant. This raises questions about what it really means that: “The results are returned securely, and both the prompt and response remain within the Microsoft 365 service boundary.”
While it is true that a user's full prompt stays inside the Microsoft 365 boundary, the derived query (after anonymization) is sent to Bing, a public service. This means some representation of the prompt’s intent leaves the Microsoft 365 boundary, even if identifiers are stripped. So, the claim that the “prompt remains within the boundary” is technically true but could be misleading because the essence of the prompt is externalized.
HIPAA compliance requires end-to-end assurance that Protected Health Information (PHI) never leaves the covered entity’s environment. If Microsoft’s legal team fully trusted the prompt language anonymization being performed by its product, it would certify Copilot Chat as HIPAA compliant. The fact that it doesn’t suggests Microsoft cannot guarantee that no PHI could ever leak through query transformation. This is our struggle as a large healthcare organization.
I have a dream that Microsoft is working on a separate Copilot Chat LLM, fully within the M365 boundary, refreshed daily with web data, eliminating the need for external grounding. That would be a game-changer for HIPAA-regulated organizations like mine. Maybe it’s just a dream, but I’ll be watching for an exciting announcement about my vision at Ignite next month! 😊
