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Starting in 2023, organisations can choose to have all Diagnostic Data, Support tickets, and Account Data processed exclusively in the EU.
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The study shows that this traffic flow is limited in scope, and contains only pseudonymous personal data (with one exception, see risk #2). Loss of control and re-identification of pseudonymous personal data due to the structural transfer of telemetry data to the US.However, there is a high risk if organisations use Teams to exchange highly sensitive and special categories of data, due to potential access by law enforcement and security agencies in the US. The result of this DPIA, after repeated consultations with Microsoft, is that there are no more known high risks resulting from the processing of the diagnostic data, if the system administrators of the organisations follow the previous recommendations about using Office 365. Six low privacy risks for diagnostic personal data Privacy Company has performed repeat inspections since 2019 to verify that Microsoft was living up to its commitments, and had taken the promised improvement measures. Microsoft has provided effective audit rights to the Dutch government. Microsoft may only process the personal data for three purposes, and is prohibited from processing any personal data for profiling, data analytics, market research or advertising. Since, Microsoft has been acting only as a data processor for all of its online services.
MICROSOFT WORD FOR GOVERNMENT EMPLOYEES SOFTWARE
The new terms apply to the Enterprise and Education versions of the Office software in use by the ministries, the tax authorities, the police, the judiciary and affiliated independent administrative bodies. In late 2019, SURF concluded the same terms for the Dutch universities. SLM Rijk concluded new privacy terms with Microsoft in early May 2019 for the 300,000 digital workstations of the central government.
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Special privacy terms for Dutch government and universities The Diagnostic Data is different from, and technically distinguishable from, the functional data that Microsoft must process (temporarily) to enable users to use Microsoft's online services over the Internet. That client is programmed to systematically collect telemetry data on the end user's device (or, from the browser in Office for the Web) and send it periodically to Microsoft's servers in the US. Microsoft collects Diagnostic Data in several technical ways, through system-generated server logs on its own cloud servers and through the so-called telemetry client built into the Teams, OneDrive and SharePoint software. For questions about the DPIA, please contact SLM Rijk (Strategic Supplier Management Microsoft, Google and AWS Rijk), which can be contacted via the Ministry of Justice press office, 00 31 70 370 73 45. You can read the complete DPIA (in English) here. We publish this blog with permission from the Ministry and SURF. This risk remains even after 2022, when Microsoft will process almost all personal data of its European Enterprise and Education customers exclusively in European data centres. This measure is necessary because of the high risk of possible access to those data from the United States. They may only do so if they can encrypt the content with encryption keys under their own control. The outcome is that Microsoft has taken measures to remedy the six high risks, but organisations should not use these cloud services to exchange or store sensitive and special categories of personal data. Commissioned by the Dutch Ministry of Justice and Security and SURF, the ICT procurement organisation for universities, Privacy Company conducted a new investigation into the privacy risks of Microsoft Teams, OneDrive and SharePoint.