GitHub Copilot
github.com
Public evidence identified as at Aug 31, 2026
Automated, point-in-time. Not independently reviewed or approved by TRUSTYCYBER unless expressly stated.
Security review required
A score is only published when there is evidence to score.
Before you sign
Why it matters: GitHub runs a dedicated Copilot trust portal, which returned no readable content to this collection across repeated attempts. What remains is the GitHub-wide privacy statement and subprocessor list, neither scoped to Copilot.
What to ask for: Please provide the GitHub Copilot Trust Center documentation covering prompt and suggestion retention, human review, and whether Business and Enterprise content is excluded from model training.
“We use Personal Data to develop and improve our products, services, and technologies, including artificial intelligence and machine learning technologies. This includes improving features, developing new offerings, enhancing safety and security capabilities, and training models. We apply appropriate technical safeguards, including aggregation and de-identification techniques where feasible, to protect your privacy while enabling these improvements.”
Why it matters: The vendor names AI-related providers or partially addresses its supply chain, but the public sources scanned do not include a formal, dated subprocessor register.
What to ask for: Request a dated subprocessor register with change-notification terms for the DPA/order form.
Why it matters: The public sources scanned do not clearly state that customer prompts, files, and outputs are excluded from training or fine-tuning of first- or third-party models.
What to ask for: Get a no-training clause covering first- and third-party models into the DPA/order form.
“We use Personal Data to develop and improve our products, services, and technologies, including artificial intelligence and machine learning technologies. This includes improving features, developing new offerings, enhancing safety and security capabilities, and training models. We apply appropriate technical safeguards, including aggregation and de-identification techniques where feasible, to protect your privacy while enabling these improvements.”
Why it matters: The public sources scanned do not give a retention period for customer data or prompts/outputs.
What to ask for: Get retention windows, in days, in writing.
Why it matters: AI is used but the public sources scanned do not name which foundation models or providers sit in the request path.
What to ask for: Require named providers and model versions, plus notice before any model change.
Buyer questionsanswered only from the public evidence scanned — click a row for the answer
!Will they train on your data?Ask the vendor
GitHub's general privacy statement reserves use of personal data to develop and improve its products and technologies, including training models, with aggregation and de-identification where feasible. The statement is organisation-wide and not scoped to Copilot.
Requires written confirmation — see Before you sign ↓
“We use Personal Data to develop and improve our products, services, and technologies, including artificial intelligence and machine learning technologies. This includes improving features, developing new offerings, enhancing safety and security capabilities, and training models. We apply appropriate technical safeguards, including aggregation and de-identification techniques where feasible, to protect your privacy while enabling these improvements.”
!How long do they keep your data?Ask the vendor
Not found in the public sources scanned — ask the vendor directly.
!Who else can access your data?Ask the vendor
GitHub publishes a subprocessor list governed by the GitHub Data Protection Agreement and publishes new subprocessors in advance.
Requires written confirmation — see Before you sign ↓
“subprocessors authorized to subprocess customer or personal data on behalf of GitHub to provide services to our Enterprise customers. This list is applicable for all GitHub services governed by the GitHub Data Protection Agreement .”
✓Where is your data processed?Clear
GitHub states Copilot can enforce geographic data residency for GitHub Enterprise Cloud customers with such requirements.
“For enterprises and organizations with data residency requirements: If you use GitHub Enterprise Cloud, Copilot can enforce geographic data residency. See GitHub Copilot with data residency .”
!What happens in a security incident?Ask the vendor
Not found in the public sources scanned — ask the vendor directly.
Confirm in writing: Ask the vendor to state this in writing before signing.
Key findingsclick a row for the evidence
✗The Copilot trust portal could not be read, and it holds the answersGap
GitHub runs a dedicated Copilot trust portal, which returned no readable content to this collection across repeated attempts. What remains is the GitHub-wide privacy statement and subprocessor list, neither scoped to Copilot.
Copilot's specific commitments — whether prompts and suggestions train models, how that differs between individual and Business or Enterprise plans, and retention — live in the portal that could not be read. This assessment is incomplete on those points; that is a statement about our collection, not about GitHub's posture.
Question for vendor: Please provide the GitHub Copilot Trust Center documentation covering prompt and suggestion retention, human review, and whether Business and Enterprise content is excluded from model training.
“We use Personal Data to develop and improve our products, services, and technologies, including artificial intelligence and machine learning technologies. This includes improving features, developing new offerings, enhancing safety and security capabilities, and training models. We apply appropriate technical safeguards, including aggregation and de-identification techniques where feasible, to protect your privacy while enabling these improvements.”
!The only training language found is organisation-wideGap
GitHub's general privacy statement reserves use of personal data for developing and improving products including training models. It governs GitHub as a whole and names Copilot only as one feature among several.
This clause can neither clear nor condemn Copilot. GitHub's published Copilot-specific position has historically been more restrictive than its general statement, so reading the general clause as Copilot policy would misrepresent it in both directions.
Question for vendor: Does the general privacy statement's training reservation apply to Copilot prompts and suggestions, and does the answer differ by plan?
“We use Personal Data to develop and improve our products, services, and technologies, including artificial intelligence and machine learning technologies. This includes improving features, developing new offerings, enhancing safety and security capabilities, and training models. We apply appropriate technical safeguards, including aggregation and de-identification techniques where feasible, to protect your privacy while enabling these improvements.”
✓Data residency exists, tied to the Enterprise Cloud tierStrong
Copilot can enforce geographic data residency for GitHub Enterprise Cloud customers.
Residency control is a real capability for regulated buyers, but it is a procurement decision rather than a setting every Copilot customer can reach.
Question for vendor: Which regions are supported, and does residency cover prompts and suggestions as well as repository content?
“For enterprises and organizations with data residency requirements: If you use GitHub Enterprise Cloud, Copilot can enforce geographic data residency. See GitHub Copilot with data residency .”
!Path-guessing on github.com returns user profiles, not policiesGap
Several candidate sources on this domain are GitHub user profile pages reached at paths like /ai, /dpa and /aup, which are usernames on github.com rather than policy pages. They carry no assurance content.
Recorded so a reader can see why this assessment is thinner than others: the collection under-represents what GitHub publishes about Copilot, and the scan is worth re-running once the trust portal is retrievable.
“GitHub Copilot is an AI coding assistant that helps you write code faster and with less effort. Then, you can focus more energy on problem solving and collaboration.”
?Technical dependency observed: Microsoft AzureObservation
Technical evidence (DNS, certificate, or HTTP) shows a dependency on Microsoft Azure as a platform provider. This dependency is not identified in the vendor's published materials.
An undisclosed provider dependency is exactly the gap independent verification exists to surface.
Question for vendor: Verification required — Microsoft Azure appears to be involved as a platform provider: confirm whether this dependency exists, and whether it processes customer data.
“subprocessors authorized to subprocess customer or personal data on behalf of GitHub to provide services to our Enterprise customers. This list is applicable for all GitHub services governed by the GitHub Data Protection Agreement .”
?Technical dependency observed: AWSObservation
Technical evidence (DNS, certificate, or HTTP) shows a dependency on AWS as a platform provider. This dependency is not identified in the vendor's published materials.
An undisclosed provider dependency is exactly the gap independent verification exists to surface.
Question for vendor: Verification required — AWS appears to be involved as a platform provider: confirm whether this dependency exists, and whether it processes customer data.
“subprocessors authorized to subprocess customer or personal data on behalf of GitHub to provide services to our Enterprise customers. This list is applicable for all GitHub services governed by the GitHub Data Protection Agreement .”
?Technical dependency observed: GoogleObservation
Technical evidence (DNS, certificate, or HTTP) shows a dependency on Google as a service provider. This dependency is not identified in the vendor's published materials.
An undisclosed provider dependency is exactly the gap independent verification exists to surface.
Question for vendor: Verification required — Google appears to be involved as a service provider: confirm whether this dependency exists, and whether it processes customer data.
“subprocessors authorized to subprocess customer or personal data on behalf of GitHub to provide services to our Enterprise customers. This list is applicable for all GitHub services governed by the GitHub Data Protection Agreement .”
?Technical dependency observed: StripeObservation
Technical evidence (DNS, certificate, or HTTP) shows a dependency on Stripe as a service provider. This dependency is not identified in the vendor's published materials.
An undisclosed provider dependency is exactly the gap independent verification exists to surface.
Question for vendor: Verification required — Stripe appears to be involved as a service provider: confirm whether this dependency exists, and whether it processes customer data.
“subprocessors authorized to subprocess customer or personal data on behalf of GitHub to provide services to our Enterprise customers. This list is applicable for all GitHub services governed by the GitHub Data Protection Agreement .”
?Technical dependency observed: MicrosoftObservation
Technical evidence (DNS, certificate, or HTTP) shows a dependency on Microsoft as a service provider. This dependency is not identified in the vendor's published materials.
An undisclosed provider dependency is exactly the gap independent verification exists to surface.
Question for vendor: Verification required — Microsoft appears to be involved as a service provider: confirm whether this dependency exists, and whether it processes customer data.
“subprocessors authorized to subprocess customer or personal data on behalf of GitHub to provide services to our Enterprise customers. This list is applicable for all GitHub services governed by the GitHub Data Protection Agreement .”
?Technical dependency observed: AtlassianObservation
Technical evidence (DNS, certificate, or HTTP) shows a dependency on Atlassian as a service provider. This dependency is not identified in the vendor's published materials.
An undisclosed provider dependency is exactly the gap independent verification exists to surface.
Question for vendor: Verification required — Atlassian appears to be involved as a service provider: confirm whether this dependency exists, and whether it processes customer data.
“subprocessors authorized to subprocess customer or personal data on behalf of GitHub to provide services to our Enterprise customers. This list is applicable for all GitHub services governed by the GitHub Data Protection Agreement .”
AI System Assurance Report Cardscored per assurance object — organisational assurance is not product, model or agent assurance
Derived from the dimensions below — expand any row for the evidence behind its grade.
Organisation & AI governance15% of the scoreorganisation-level evidence0
Graded from organisation-level evidence — it does not automatically establish assurance for this product.
Who owns AI risk — policies, responsible-AI principles, human oversight and administrative controls.
Assessed against ISO 42001 · NIST AI RMF · AIUC-1
Governance & accountability: not publicly evidenced.
AI system15% of the score13
What AI the vendor actually runs and where it sits in the product — the map everything else is judged against.
Assessed against ISO 42001 · NIST AI RMF
“GitHub Copilot is an AI coding assistant that helps you write code faster and with less effort. Then, you can focus more energy on problem solving and collaboration.”
How AI features are evaluated before and after release — evals, red-teaming, monitoring.
Assessed against NIST GenAI · NIST AI RMF · ISO 42001
How changes to models and AI features are controlled and communicated — versioning, notice, rollback.
Assessed against ISO 27001 · ISO 42001
Testing & evaluation: not publicly evidenced.
Change management: not publicly evidenced.
Model10% of the scoreorganisation-level evidence0
Graded from organisation-level evidence — it does not automatically establish assurance for this product.
Which model providers and versions process customer data, and how changes to them are disclosed.
Assessed against NIST GenAI · ISO 42001
Model provider transparency: not publicly evidenced.
Customer data15% of the score52
Whether customer data trains models, how long it is retained, where it is processed, and how it is protected.
Assessed against ISO 27018 · OAIC APPs · EU AI Act
“For enterprises and organizations with data residency requirements: If you use GitHub Enterprise Cloud, Copilot can enforce geographic data residency. See GitHub Copilot with data residency .”
“We use Personal Data to develop and improve our products, services, and technologies, including artificial intelligence and machine learning technologies. This includes improving features, developing new offerings, enhancing safety and security capabilities, and training models. We apply appropriate technical safeguards, including aggregation and de-identification techniques where feasible, to protect your privacy while enabling these improvements.”
AI supply chain10% of the scoreorganisation-level evidence40
Graded from organisation-level evidence — it does not automatically establish assurance for this product.
The named chain of AI and infrastructure providers behind the product, and how it is disclosed.
Assessed against ISO 27001 · ISO 27017
“subprocessors authorized to subprocess customer or personal data on behalf of GitHub to provide services to our Enterprise customers. This list is applicable for all GitHub services governed by the GitHub Data Protection Agreement .”
Security foundation15% of the scoreorganisation-level evidence24
Graded from organisation-level evidence — it does not automatically establish assurance for this product.
How security problems are found, reported and handled — disclosure channels, bug bounty, incident response.
Assessed against ISO 27001 · NIST AI RMF
Vulnerability & incident handling: not publicly evidenced.
Independent assurance evidence10% of the scoreorganisation-level evidence63
Graded from organisation-level evidence — it does not automatically establish assurance for this product.
Whether claimed certifications and attestations are independently corroborated — checked against official registries and issuing bodies. Which certifications, and what each one does and does not establish, is stated per certificate.
Assessed against ISO 17021-1 · ISO 42006 · ISO 27006-1 · ISO 27008
Read from the registry record above — cited, not reproduced.
Read from the registry record above — cited, not reproduced.
Read from the registry record above — cited, not reproduced.
None of the corroborated certifications is AI-specific (ISO/IEC 42001 or AIUC-class) — this assurance is security and data-transfer attestation, not AI-management-system assurance.
Legal & contractual10% of the scoreorganisation-level evidence0
Graded from organisation-level evidence — it does not automatically establish assurance for this product.
The contractual backbone a buyer can rely on — terms, DPAs, privacy commitments and regulatory posture.
Assessed against EU AI Act · OAIC APPs
Legal & contractual transparency: not publicly evidenced.
Not graded: Agent — not applicable to this scan.
AI supply chainclick a node to focus it · drag to pan · zoom with the controls
View as list
What you inheritTrustyCyber's AI Shared Responsibility Matrix v1.0
This scan names the vendor’s AI supply chain without assessing the responsibility split — that depends on how you consume the product. Under the common managed models, a deployer inherits 16 of the matrix’s 41 responsibilities from providers, each with named evidence owed.
Map your inherited responsibilitiesAssurance evidence: certifications 4 — registry checks and verification ladders, click to view
Not claimed in any public source scanned. This is the AI-management-system certification — in its absence, the vendor’s AI governance rests on its general security and privacy certifications.
Checked against Data Privacy Framework (dataprivacyframework.gov), Aug 31, 2026: Verified on the registry
Checked against CSA STAR Registry, Aug 31, 2026: Verified on the registry
Checked against FedRAMP Marketplace (fedramp.gov), Aug 31, 2026: Verified on the registry
Sources 15 — click to view
Appendix: standards landscape 8 — click to view
Where each standard behind this assessment stands today, from TrustyCyber’s continuously maintained standards radar.
This automated result is based on publicly available information at the time of scanning. It is not an audit, certification, legal opinion or assurance engagement. Publicly unavailable evidence may materially change the conclusion.
