Request for Clarification on Azure OpenAI Global Standard Deployment – Data Residency & Processing

Question

Request for Clarification on Azure OpenAI Global Standard Deployment – Data Residency & Processing

Azimi, Zoey 0

Hi,

I am currently evaluating the Azure OpenAI Service for internal use within my company, which is based in Germany and must comply with strict legal frameworks including the EU General Data Protection Regulation (GDPR) and the upcoming EU AI Act.

From the official documentation, I understand that in Global Standard deployment mode, model inference occurs in the selected Azure region (e.g., EU or US). However, prompts and completions may be logged and stored temporarily for abuse monitoring, and some supporting services (telemetry, logging, moderation) may operate outside the region.

To ensure alignment with our internal policies and regulatory obligations, I would appreciate clarification on the following points:

Which countries and data centers may be involved in processing data (e.g., prompts, completions, telemetry, logs) under the Global Standard mode, specifically for:
- Core model inference
- Abuse detection
- Telemetry, logging, and content moderation
Are any Microsoft-operated or third-party services located outside the EU or US (e.g., in Asia, Latin America, or Africa) involved in:
- Data routing or logging
- Abuse monitoring
- Service health monitoring
- Customer support diagnostics
Does Microsoft provide a detailed Data Flow Diagram or Architecture Document that maps how data flows through systems and geographies under the Global Standard deployment?
Under which contractual safeguards (e.g., Standard Contractual Clauses, DPA, BAA) is data managed in Global Standard mode to ensure GDPR compliance?
Is there an option to opt out of logging/abuse monitoring, or to implement additional protections like Azure Private Link or customer-managed keys?

I would be grateful for any references to:

A Data Flow Diagram or equivalent documentation showing service geography
Any relevant compliance-focused whitepapers, DPAs, or customer assurance guides for the Azure OpenAI Service

Thank you for your time and guidance

kothapally Snigdha 3,020 Reputation points Microsoft External Staff Moderator

2025-03-25T21:45:02.8466667+00:00
Hi Azimi, Zoey

The Azure OpenAI Service operates under specific data processing guidelines, particularly in relation to the Global Standard deployment mode. Here are the clarifications regarding your questions:

Countries and Data Centers Involved

In Global Standard deployment mode, core model inference occurs in the selected Azure region (e.g., EU or US). However, prompts and completions may be processed in any geography where the relevant Azure OpenAI model is deployed.

For abuse detection, a sample of customer prompts and completions may be reviewed, and this data is stored in the Azure geography where the customer’s Azure OpenAI resource is deployed.

Telemetry, logging, and content moderation may involve processing in various Azure data centers, but specific countries outside the EU or US are not detailed in the provided context.

Microsoft-operated or Third-party Services:

The context does not specify whether any Microsoft-operated or third-party services located outside the EU or US are involved in data routing, logging, abuse monitoring, service health monitoring, or customer support diagnostics.

Data Flow Diagram or Architecture Document:

The context does not mention the availability of a detailed Data Flow Diagram or Architecture Document that maps how data flows through systems and geographies under the Global Standard deployment.

Contractual Safeguards:

The context does not provide explicit details regarding the contractual safeguards (such as Standard Contractual Clauses, DPA, BAA) for data management in Global Standard mode to ensure GDPR compliance.

Opting Out of Logging/Abuse Monitoring:

The context does not indicate whether there is an option to opt out of logging or abuse monitoring, or to implement additional protections like Azure Private Link or customer-managed keys.

kindly refer these https://learn.microsoft.com/en-us/legal/cognitive-services/openai/data-privacy?tabs=azure-portal#how-does-the-azure-openai-service-process-data

I hope these helps you. Thank you!
kothapally Snigdha 3,020 Reputation points Microsoft External Staff Moderator

2025-03-26T20:45:17.24+00:00

Hi Azimi, Zoey

following up to see of the above response was helpful.
kothapally Snigdha 3,020 Reputation points Microsoft External Staff Moderator

2025-03-27T21:06:47.12+00:00

Hi Azimi, Zoey

We haven’t heard from you on the last response and was just checking back to see if you have a resolution yet. In case if you have any resolution, please do share that same with the community as it can be helpful to others. Otherwise, will respond with more details and we will try to help.
Azimi, Zoey 0 Reputation points

2025-04-02T08:31:22.69+00:00
Hi again,
Thank you for the detailed documentation and the diagrams, and also the follow up. Indeed, some of the points you have mentioned has helped clarify several important points.

From what I understood:

Global deployments may involve processing in any geography where Azure OpenAI models are deployed.

Abuse monitoring can be turned off upon approval, and this setting can be verified via the ContentLogging flag.

Data is not shared with OpenAI or used for model training, which is important for GDPR alignment.

There are just a few remaining questions I hope to clarify:

Could Microsoft share a list or reference of specific regions (beyond EU/US) where Global deployments may process prompts/completions?

Are any third-party services or vendors involved in abuse detection, telemetry, logging, or diagnostics—especially in non-EU/US locations?

Does Microsoft rely on Standard Contractual Clauses, the DPA, or any other explicit legal basis for data transfers in Global deployment scenarios, especially for processing that occurs outside the EU/US?

Thanks again for your help. These final details will really support our internal DPIA and regulatory alignment process.
kothapally Snigdha 3,020 Reputation points Microsoft External Staff Moderator

2025-04-04T01:25:48.9066667+00:00
Hi Azimi, Zoey

You're welcome! I'm glad the information has been helpful so far.

Azure OpenAI models are deployed across various regions globally. While specific regions beyond the EU and US aren't explicitly listed in the documentation I found, Azure's global infrastructure includes regions like Australia East, Japan East, South India, and Sweden Central, among others.

Microsoft employs robust mechanisms for abuse detection, telemetry, and diagnostics. While the documentation doesn't explicitly mention third-party involvement in non-EU/US locations, Microsoft Defender for Cloud Apps and other tools are used to monitor and manage risks. For precise details, contacting Microsoft directly would be the best approach.

Microsoft relies on Standard Contractual Clauses (SCCs) and the Data Protection Addendum (DPA) to ensure compliance with GDPR and other data protection regulations for data transfers outside the EU/US. These mechanisms provide guarantees for lawful data processing and transfers.

I Hope these helps you. let me know do you have any further queries.

Thank you!
kothapally Snigdha 3,020 Reputation points Microsoft External Staff Moderator

2025-04-07T01:06:25.29+00:00

Hi Azimi, Zoey

We haven’t heard from you on the last response and was just checking back to see if you have a resolution yet. In case if you have any resolution, please do share that same with the community as it can be helpful to others. Otherwise, will respond with more details and we will try to help.

Your answer

kothapally Snigdha 3,020 Reputation points Microsoft External Staff Moderator

2025-03-26T20:45:17.24+00:00

Hi Azimi, Zoey

following up to see of the above response was helpful.
kothapally Snigdha 3,020 Reputation points Microsoft External Staff Moderator

2025-03-27T21:06:47.12+00:00

Hi Azimi, Zoey

We haven’t heard from you on the last response and was just checking back to see if you have a resolution yet. In case if you have any resolution, please do share that same with the community as it can be helpful to others. Otherwise, will respond with more details and we will try to help.
Azimi, Zoey 0 Reputation points

2025-04-02T08:31:22.69+00:00

Hi again,
Thank you for the detailed documentation and the diagrams, and also the follow up. Indeed, some of the points you have mentioned has helped clarify several important points.

From what I understood:

Global deployments may involve processing in any geography where Azure OpenAI models are deployed.

Abuse monitoring can be turned off upon approval, and this setting can be verified via the ContentLogging flag.

Data is not shared with OpenAI or used for model training, which is important for GDPR alignment.

There are just a few remaining questions I hope to clarify:

Could Microsoft share a list or reference of specific regions (beyond EU/US) where Global deployments may process prompts/completions?

Are any third-party services or vendors involved in abuse detection, telemetry, logging, or diagnostics—especially in non-EU/US locations?

Does Microsoft rely on Standard Contractual Clauses, the DPA, or any other explicit legal basis for data transfers in Global deployment scenarios, especially for processing that occurs outside the EU/US?

Thanks again for your help. These final details will really support our internal DPIA and regulatory alignment process.
kothapally Snigdha 3,020 Reputation points Microsoft External Staff Moderator

2025-04-04T01:25:48.9066667+00:00

Hi Azimi, Zoey

You're welcome! I'm glad the information has been helpful so far.

Azure OpenAI models are deployed across various regions globally. While specific regions beyond the EU and US aren't explicitly listed in the documentation I found, Azure's global infrastructure includes regions like Australia East, Japan East, South India, and Sweden Central, among others.

Microsoft employs robust mechanisms for abuse detection, telemetry, and diagnostics. While the documentation doesn't explicitly mention third-party involvement in non-EU/US locations, Microsoft Defender for Cloud Apps and other tools are used to monitor and manage risks. For precise details, contacting Microsoft directly would be the best approach.

Microsoft relies on Standard Contractual Clauses (SCCs) and the Data Protection Addendum (DPA) to ensure compliance with GDPR and other data protection regulations for data transfers outside the EU/US. These mechanisms provide guarantees for lawful data processing and transfers.

I Hope these helps you. let me know do you have any further queries.

Thank you!
kothapally Snigdha 3,020 Reputation points Microsoft External Staff Moderator

2025-04-07T01:06:25.29+00:00

Hi Azimi, Zoey

We haven’t heard from you on the last response and was just checking back to see if you have a resolution yet. In case if you have any resolution, please do share that same with the community as it can be helpful to others. Otherwise, will respond with more details and we will try to help.

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Request for Clarification on Azure OpenAI Global Standard Deployment – Data Residency & Processing

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