Microsoft 365: DPA, subprocessors and transfers

What to put in your subprocessor list

A ready row. Replace the purpose with what your client actually uses Microsoft 365 for.

Questions people ask about Microsoft 365

Where is Microsoft 365's DPA?

Microsoft 365 publishes its customer data processing agreement at https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA. We last opened that link on 1 November 2026.

Is Microsoft 365's DPA the same thing as a data processing addendum?

Yes. A data processing agreement and a data processing addendum are two names for the document Article 28 of the GDPR requires between a controller and a processor; vendors use both, and some call it processor terms. What it has to contain does not change with the name. Microsoft 365's is at https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA.

Which legal entity does Microsoft 365 contract through?

Microsoft Ireland Operations Limited, registered in Ireland. That is the name to put in a record of processing or a sub-processor list, not the brand.

Does sending personal data to Microsoft 365 count as a transfer out of the EEA?

No. Microsoft Ireland Operations Limited is registered in Ireland, inside the EEA, so no transfer mechanism is needed to reach it. Where it sends personal data on to is a separate question, and one for its own sub-processor list.

Where is Microsoft 365's trust center?

Microsoft 365 publishes it at https://www.microsoft.com/en-us/trust-center. A trust center, trust page or security page is the same thing under different names: the vendor's own account of how it protects data, and the place it keeps its certifications. It is Microsoft 365's page, so we link to it rather than repeat what it says.

Where to go next

Worked out from the registry and what we have written: the country this vendor contracts from, the guides that answer the question this page raises, and the rest of the registry.

• Vendors contracting from Ireland32 in the registry
• What to tell a client with an Irish entity about NIS2Ireland has not transposed NIS2, so there are no national duties yet — what is live instead, what to do meanwhile, and w
• The vendor registryLegal entities, transfer mechanisms and DPA links, checked by a person
• Download the registry as a CSVFree, for a spreadsheet
• Guides for privacy practicesHow the work is actually done

Other workplace tools

Six of them. All workplace tools in the registry · others that transfer the same way.

• 1PasswordCA
• AirtableUS
• AsanaUS
• AssembledUS
• AtlassianAU
• BitwardenUS