Field note
Copilot Usage Exports: UK Privacy Checks
De-identified does not mean anonymous in a 30 person firm; decide who can export Copilot usage data and why before anyone downloads it.
De-identified does not mean anonymous in a 30 person firm; decide who can export Copilot usage data and why before anyone downloads it.
What the exports contain
Microsoft offers two related exports.
Copilot Dashboard export. Microsoft Learn describes a download of user-level Copilot metrics: week-level data for the past six months, or day-level data for the past 28 days. Personal identifiers are replaced with anonymised IDs unless an administrator has enabled identifiable export for that user. The file includes metrics such as prompts submitted and actions taken per app, active days, Copilot Chat use by unlicensed users, and returning user measures, plus two HR attributes: Organization and FunctionType. The Learn page still labels the feature as preview and notes that it allows personal data processing.
Agent Dashboard export. Message centre post MC1288531 describes an export of de-identified, user-level Copilot agent metrics and agent attributes, aggregated by user and week, for up to six months. It lists general availability rolling out from late September 2026 to early October 2026.
Both require a tenant of at least 50 licences. The Learn page says 50 Copilot or Viva Insights licences; the agent export post says 50 Microsoft 365 Copilot licences. Smaller tenants will not see the feature at all.
Who can export by default
Access follows global access to the Copilot Dashboard:
- Senior leaders identified automatically from Entra ID data.
- Users an admin has given global access.
- Delegates of those users, who inherit export access unless disabled.
- Viva Insights analysts with global access and Microsoft 365 Global Administrators.
Managers with team-level views cannot export. Both features are on by default for eligible users. Admins can switch them off for the tenant or for groups through Viva Feature Access Management in the Microsoft 365 admin center, and changes can take up to 24 hours.
Why de-identified is not the end of the question
A hashed ID plus an Organization value and a job function can point to one person in a small team. If your finance department has three people and one job function is "Credit control", the row is effectively identified. The ICO treats pseudonymised data as personal data under UK GDPR, so plan on the basis that these exports are personal data.
The ICO's employment guidance on monitoring workers covers this directly. It sets out that employers must comply with UK GDPR and the Data Protection Act 2018 when monitoring workers, should be transparent with them, and should keep monitoring necessary and proportionate. The ICO notes the guidance is under review following the Data (Use and Access) Act, so check it for updates before relying on detail.
Steps before anyone exports
- Decide the purpose. "Understand which teams are not using the licences we pay for" is a defensible purpose. "Rank individuals by prompts per day" is performance monitoring and needs a much stronger justification.
- Restrict access. Use Viva Feature Access Management to limit export to a named group, and review who holds delegated access.
- Leave identifiable export off unless you have a specific, documented need.
- Run a data protection impact assessment if the data could be used to judge individuals. The ICO expects one where monitoring is likely to result in high risk to workers.
- Tell staff. Update your privacy notice and acceptable use policy to explain that Copilot usage is measured, at what level and why.
- Set retention. Exports are point-in-time files that are not updated. Store them in one controlled location and delete them when the analysis is done.
Our note on AI chatbot HR data boundaries covers the wider question of AI and employee data.
Use the data for licensing, not scoring
The useful questions for an SME are simple:
- Which licensed users have had Copilot enabled but show no active days? That is a training or reallocation question.
- Which apps are used, and which are ignored? That shapes your training plan.
- Are unlicensed staff using Copilot Chat heavily? That may justify a licence, or a policy conversation.
Aggregate before sharing. Present results at team level with small groups merged, and do not pass row-level files to line managers.
Keep the controls under review
- Check the Viva feature access settings each quarter, and after any change in leadership roles, since senior leader access is derived from Entra ID.
- Re-read the Learn page when the Copilot Dashboard export leaves preview; terms and fields can change.
- Record each export in a simple log: date, who, purpose and deletion date.
If you are also reviewing where Copilot can see sensitive files, our guide to Purview DSPM for AI is a sensible next step.