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    Purview DLP and sensitivity labels for Microsoft 365 Copilot

    Microsoft 365 Copilot is governed in Purview DLP through its own policy location, named Microsoft 365 Copilot and Copilot Chat, where the tenant is licensed for it. Microsoft creates a default policy for Copilot interactions that covers every user and group in the tenant and runs in simulation mode, so a match raises an alert and nothing is blocked. Sensitivity labels sit alongside DLP and decide how protected content behaves when Copilot retrieves it. The settings to confirm are whether a Copilot policy exists, whether it enforces, who can edit it, and whether labels are applied to the content Copilot can reach.

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    1. Purview DLP and sensitivity labels for Microsoft 365 Copilot
    2. Why DLP and labels matter once Copilot is licensed
    3. Where the Copilot DLP policy location sits
    4. What the default Copilot DLP policy does
    5. Who can create or edit a Copilot DLP policy
    6. How sensitivity labels affect what Copilot returns
    7. Where retention and audit fit around Copilot interactions
    8. What permissions, identity and guests add to the picture
    9. Checklist: DLP, label and tenant settings to confirm for Copilot

    Purview DLP and sensitivity labels for Microsoft 365 Copilot

    Microsoft 365 Copilot is governed in Purview DLP through its own policy location, named Microsoft 365 Copilot and Copilot Chat, where the tenant is licensed for it. Microsoft creates a default policy for Copilot interactions that covers every user and group in the tenant and runs in simulation mode, so a match raises an alert and nothing is blocked. Sensitivity labels sit alongside DLP and decide how protected content behaves when Copilot retrieves it.

    The settings to confirm are whether a Copilot policy exists, whether it enforces, who can edit it, and whether labels are applied to the content Copilot can reach.

    Why DLP and labels matter once Copilot is licensed

    Copilot answers a prompt from Microsoft Graph and the semantic index built over your tenant. It runs in the security context of the person asking, and results are trimmed to what that account could already open. Copilot does not widen access. It removes the effort of finding content. Before a rollout, an over-permissioned site was protected mostly by obscurity, because staff only opened the folders they already knew about.

    With Copilot, one prompt can pull an answer from any document the account can open, including documents the person has never seen.

    Permissions decide what Copilot can retrieve. DLP and sensitivity labels decide what happens when sensitive content turns up in a prompt or an answer.

    • Content source: SharePoint sites and libraries

      What decides reach
      Site membership, sharing links, inheritance
      What to read
      Site permissions, sharing links, group membership
    • Content source: OneDrive

      What decides reach
      Files shared out by each owner
      What to read
      Sharing links, especially organisation-wide and Anyone links
    • Content source: Teams and Microsoft 365 groups

      What decides reach
      Team membership
      What to read
      Guest membership, owner coverage
    • Content source: Agents

      What decides reach
      Credential option, knowledge sources, sharing
      What to read
      Maker credential agents, agents shared with everyone
    Why DLP and labels matter once Copilot is licensed

    Where the Copilot DLP policy location sits

    Where the tenant is licensed for it, Purview DLP has a dedicated policy location for Copilot, named Microsoft 365 Copilot and Copilot Chat. It is available only in the Custom policy template. Selecting it switches off every other location in the same policy.

    A Copilot DLP policy is therefore a policy of its own. The policies that protect Exchange, SharePoint, OneDrive and Teams do not carry over to Copilot interactions by adding a location to them. Plan the Copilot policy as a separate object with its own owner, its own mode and its own review date, and record it in the same register as the other DLP policies.

    What the default Copilot DLP policy does

    Microsoft creates a default policy named Default DLP policy - Protect sensitive M365 Copilot interactions. Its settings are fixed at creation and stay that way until someone changes them.

    A tenant that never switched the default policy to enforce mode is logging those information types in prompts and stopping none of them. Read the policy's mode before treating it as a control. The alerts raised in simulation show which information types appear in prompts across the organisation, and that record is the evidence for deciding which conditions to enforce and for whom.

    Changing the mode is a decision for the policy owner, taken with the business areas that handle the information types concerned. A tax file number in a payroll team's prompts has a different meaning from the same number appearing in a general staff prompt.

    • Property: Scope

      Default value
      Every user and group in the tenant
    • Property: Mode

      Default value
      Simulation
    • Property: Effect of a match

      Default value
      An alert is raised and nothing is blocked
    • Property: Australian sensitive information types

      Default value
      Australia Tax File Number, Australia Medical Account Number, Australian Business Number, Australian Company Number
    What the default Copilot DLP policy does

    Who can create or edit a Copilot DLP policy

    The Purview or Entra AI roles that can create or edit a Copilot DLP policy are separate from the SharePoint and Exchange administrator roles. An administrator who runs SharePoint does not, by holding that role, control the Copilot policy. The holders of the Purview and AI roles form their own list, and that list needs the same review as any other privileged assignment.

    An account holding Global Administrator, SharePoint Administrator or a Purview role can change the controls that limit Copilot's reach. List every standing assignment to those roles and check it against PIM, admin roles and break-glass accounts. An assignment left standing after a project ended is one of the defects Copilot makes easier to exploit.

    How sensitivity labels affect what Copilot returns

    Microsoft's Purview sensitivity label documentation states that where a label applies encryption, Copilot returns content from that item only when the user holds the usage rights to view and extract it. The same documentation states that content Copilot creates from labelled sources inherits the highest priority label among them.

    Labels only do that work on content that carries them. An unlabelled file is governed by its permissions alone. Three settings decide how much of the tenant's sensitive content is labelled:

    Check the label policies and the library settings together. A published taxonomy with no defaults and no auto-labelling leaves labelling to individual staff decisions, file by file.

    • A label taxonomy that is published to users and used in practice.
    • Default labels on the sensitive sites and libraries, so new files start labelled.
    • Auto-labelling rules that cover the information types the organisation holds.

    Where retention and audit fit around Copilot interactions

    Microsoft's Purview retention documentation states that Copilot prompts and responses are stored in a hidden folder in the user's mailbox, and that Purview retention policies have a location for Copilot interactions. Compare that retention policy with the organisation's records obligations, so prompts and responses are kept for as long as required and deleted on schedule.

    Microsoft's Purview audit documentation describes a Copilot interaction event in the unified audit log. Confirm auditing is turned on, that audit retention suits the organisation's investigation needs, and that the events reach whatever system the security team monitors.

    What permissions, identity and guests add to the picture

    DLP acts on what Copilot retrieves, and retrieval follows permissions. The patterns that widen retrieval in SharePoint and OneDrive are the Everyone except external users group in a site's membership or a library's permissions, Anyone and organisation-wide sharing links on restricted material, and inheritance broken somewhere under a large audience.

    Restricted Content Discovery is the SharePoint setting tenants reach for part-way through a rollout. It drops a site out of organisation-wide search and the tenant-wide discovery Copilot answers from. Content a person owns or already has open stays reachable, nothing is removed from the search index, and the site's permissions are unchanged. The setting needs a Microsoft Copilot licence and SharePoint Advanced Management. It applies to a ceiling of 20,000 sites, and a site over 500,000 items can take more than a week to drop out of search and Copilot.

    Microsoft documents it as a temporary governance control. Treat each restricted site as an open finding with a named owner and a date for fixing the underlying permissions.

    Copilot inherits identity controls from Entra ID. The review reads each Conditional Access policy and its exclusions. It checks MFA coverage across every account that matters, including break-glass accounts.

    Application consent matters because third-party apps, connectors and agents can hold Graph permissions such as read access to every site. List applications with tenant-wide read permissions and check who granted them, using the method in app consent and service principals in Entra.

    Guest accounts widen the audience for content in any team or site they are added to. Remove guests with no recent sign-in, map guests out of sites that hold sensitive content, and review the Entra cross-tenant access settings.

    Checklist: DLP, label and tenant settings to confirm for Copilot

    Run this before Copilot licences are assigned, and again once remediation lands. Permission changes in SharePoint and Entra take time to propagate through the search index, so the second pass confirms each fix is live.

    Black Shard's Microsoft Copilot security review covers Conditional Access, privileged roles, app consent, SharePoint and OneDrive sharing, Copilot DLP, agents and Restricted Content Discovery with reader-level access, delivers the findings with a remediation plan, and re-checks the tenant once the fixes are in place.

    • Area: DLP

      Setting to confirm
      Copilot location policy exists and enforces
      Evidence
      Policy mode and conditions
    • Area: DLP

      Setting to confirm
      Default Copilot policy mode reviewed and owned
      Evidence
      Policy list and simulation alerts
    • Area: DLP roles

      Setting to confirm
      Purview and AI role holders listed and justified
      Evidence
      Role assignment report
    • Area: Sensitivity labels

      Setting to confirm
      Labels published, defaults set on sensitive libraries
      Evidence
      Label policy and library settings
    • Area: Sensitivity labels

      Setting to confirm
      Auto-labelling covers the information types held
      Evidence
      Auto-labelling policies
    • Area: Retention

      Setting to confirm
      Copilot interaction retention matches records obligations
      Evidence
      Retention policy
    • Area: Audit

      Setting to confirm
      Auditing on, Copilot events reaching monitoring
      Evidence
      Audit search and log pipeline
    • Area: SharePoint and OneDrive

      Setting to confirm
      No Everyone except external users grants on sensitive sites
      Evidence
      Site permission export
    • Area: SharePoint and OneDrive

      Setting to confirm
      Anyone and organisation-wide links removed from restricted content
      Evidence
      Sharing link report
    • Area: Restricted Content Discovery

      Setting to confirm
      Each restricted site has an owner and a fix date
      Evidence
      Purview audit events and register
    • Area: Conditional Access

      Setting to confirm
      MFA covers every account, break-glass exclusions justified
      Evidence
      Policy export
    • Area: Privileged roles

      Setting to confirm
      Standing high-impact assignments removed or justified
      Evidence
      Role assignment report
    • Area: App consent

      Setting to confirm
      Tenant-wide read grants reviewed and owned
      Evidence
      Enterprise applications list
    • Area: Guests

      Setting to confirm
      Stale guests removed, guests mapped out of sensitive sites
      Evidence
      Guest inventory and sign-in data
    • Area: Agents

      Setting to confirm
      Maker credential agents listed, no agent shared with everyone without review
      Evidence
      Agent inventory
    Checklist: DLP, label and tenant settings to confirm for Copilot

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