Control 4.6: Grounding Scope Governance — Troubleshooting

This playbook provides FSI-grade troubleshooting for Control 4.6 — Grounding Scope Governance.

Last UI Verified: April 2026 Audience: SharePoint Admin, Power Platform Admin, Purview Compliance Admin, AI Governance Lead, Compliance Officer, Privacy Officer, Incident Response Lead. Sovereign clouds covered: Commercial, GCC, GCC High, DoD (parity caveats noted in §4). Severity-of-control statement. Grounding-scope failures expose the firm to: customer NPI / MNPI / supervisory-record / draft-filing disclosure via Microsoft 365 Copilot; loss of supervisory visibility; books-and-records integrity gaps. Treat suspected scope leaks as cybersecurity events first, configuration issues second.

Disclaimer. This playbook supports compliance with FINRA, SEC, NY DFS, GLBA, OCC, Fed, and CFTC requirements; it does not by itself satisfy any regulatory obligation. Implementation requires firm-specific policy, role assignment, and Compliance / Legal review. Microsoft does not publish per-incident SLAs for grounding-scope misconfiguration; all response windows below are firm-defined targets, not vendor commitments.

§1 — FSI Incident Handling — READ THIS FIRST

A confirmed grounding-scope failure is, by default, treated as a potential NY DFS 23 NYCRR 500 §500.17(a) cybersecurity event, a potential SEC Regulation S-P §248.30(a)(4) customer-notification event (where customer NPI is implicated), a FINRA Rule 4511 / SEC 17a-4(f) books-and-records integrity event, and — where the agent involved is in scope of the firm's supervisory program — a FINRA Rule 3110 / FINRA 25-07 AI-supervision event. Engineering does not make any reportability decision. Engineering's job is to (a) preserve evidence, (b) put compensating controls in place, (c) escalate to Compliance, Legal, Privacy, and the CISO per the matrix below.

1.1 Severity matrix — grounding-scope events

Severity	Trigger	Firm-defined response window	Escalation
SEV-1	Confirmed disclosure via Microsoft 365 Copilot, a Copilot Studio agent, or Business Chat of: customer NPI; draft regulatory filing; supervisory record; MNPI / restricted-list / watch-list content; insider list; PII; OR a reproducible bypass of an in-effect RCD or RSS scope on a Zone 3 workload; OR personal OneDrive content surfaced inside a published declarative agent	Immediate (sample target ≤ 1 h to acknowledge)	CISO + Compliance Officer + General Counsel + Privacy Officer within 1 h (firm-defined)
SEV-2	RCD or RSS configuration regressed on an in-scope site (no confirmed disclosure yet); DLP-for-Copilot connector block bypassed via a direct-URL knowledge source; Copilot Studio knowledge source pointing at an unsanctioned site discovered in inventory; suspected scope leak under investigation	Sample target ≤ 4 h	AI Governance Lead + SharePoint Admin + Power Platform Admin
SEV-3	RSS allow-list ceiling reached blocking a sanctioned business request; classic-page indexing gap on a single site; DAG report stale beyond the documented Microsoft Learn cadence; Copilot Studio knowledge source change not visible after the documented sync window	Sample target ≤ 1 business day	SharePoint Admin
SEV-4	Cosmetic / preview-feature regression; single-user "I cannot see content I should" on a non-regulated site	Best effort	Track in known-issues log; review at next governance cadence

Response windows above are firm-defined sample targets for FSI environments. Microsoft does not publish per-incident SLAs for grounding-scope misconfiguration. Adjust to your firm's IR runbook and supervisory commitments.

1.2 Reportability decision tree (escalate; do not decide internally)

Trigger	Escalate to	Possible obligation (Legal owns the determination)
Customer NPI / PII surfaced via Copilot grounding	Privacy Officer + General Counsel	GLBA 501(b); SEC Regulation S-P §248.30(a)(4) customer-notification (30 days from determination of misuse / reasonable likelihood of misuse)
Cybersecurity event materially affecting normal operations OR involving NPI of a NY-resident consumer	CISO + General Counsel	NY DFS 23 NYCRR 500 §500.17(a) — 72-hour Superintendent notification (clock starts at determination, not first alert)
Loss of supervisory visibility on AI-surfaced communications (e.g., grounding scope drifted such that Communication Compliance no longer covers the surface)	Compliance Officer	FINRA Rule 3110 supervisory system; FINRA Notice 25-07 AI / agent supervision reminder
Books-and-records gap (RCD or RSS change not auditable; grounding-scope change not retained)	Compliance Officer + General Counsel	FINRA Rule 4511 / SEC 17a-4(f) books-and-records integrity
Insider misconduct using Copilot to bypass a known RCD scope	HR + General Counsel + Compliance Officer	FINRA Rule 4530(b) disclosure obligations; firm misconduct reporting
Records event affecting covered swap / trading content	Compliance Officer	CFTC Rule 1.31 record retention
Agent grounded on uncontrolled scope and deployed to production (operational risk from the model surface itself)	Model Risk + Compliance Officer	OCC Bulletin 2011-12 / Fed SR 11-7 model risk management
Aggregated AI-surfaced data reaches financial-disclosure-adjacent processes	Internal Audit + Compliance Officer	SOX §302 / §404 ICFR

Engineering rule. Engineering surfaces facts to Compliance / Legal / Privacy. Engineering does not assert "this is not a reportable event."

1.3 Evidence preservation — capture before remediation

Capture all of the following before any change is made, in this order. Hash each artifact (SHA-256) and record the storage location in the evidence pack.

Screenshots of: SharePoint Admin Center site detail page showing RestrictContentOrgWideSearch state; tenant Restricted SharePoint Search (RSS) state; Copilot Studio knowledge-source list per affected environment; the actual Copilot citation in Business Chat showing the leaked content (with timestamp visible).
Get-SPOSite -Identity <url> | Select Url, RestrictContentOrgWideSearch, LockState, LastContentModifiedDate, Status — full output for every affected site.
Get-SPOTenant | Select EnableRestrictedSearchAllList, *Search*, *Copilot*, *AI* — tenant-level state snapshot.
Get-SPOTenantRestrictedSearchAllowedList — full allow-list export with row count and SHA-256 sidecar.
Get-MgSubscribedSku | Select SkuPartNumber, ConsumedUnits, PrepaidUnits — Copilot SKU presence and consumption (rules in / rules out F3 silent no-op).
Copilot Studio knowledge-source inventory per environment (Power Platform Admin Center export and / or Get-PowerPlatformEnvironment plus per-environment knowledge-source list).
Unified Audit Log search for SharePointFileOperation, CopilotInteraction (and the documented Copilot / agent activity event names current at the time), and SPO admin events for the affected window — paginated CSV / JSON export with SHA-256 sidecar.
Data Access Governance (DAG) report for the affected sites at time of detection — capture report generation timestamp, not just download timestamp.
DLP-for-Copilot policy snapshot: Get-DlpCompliancePolicy, Get-DlpComplianceRule for any policy with the Copilot location enabled.
Zone classification register entry for the affected site / agent (per Control 2.1).
Tenant ID, cloud (Commercial / GCC / GCC High / DoD), UTC window of the incident, role used for capture, requesting user, affected user(s), and citation URL(s).
Record-retention proof: confirmation that the audit window covering the change is within retention (per Control 1.7) and that holds (per Control 1.13 / 1.14) are in place if litigation or examination is foreseeable.
Page composition snapshot for the affected site (modern vs classic ASPX) to rule in / rule out F10.

1.4 Compensating controls — apply during the gap

Apply as many as are operationally feasible without destroying evidence. Document each in the incident timeline.

Tighten DLP-for-Copilot (Control 1.5) on the affected sensitive information type / sensitivity label from TestWithNotifications to Enable (Block) on the Copilot location.
Freeze new Copilot Studio publishes touching the affected site or scope (Control 2.1 environment governance freeze).
Run daily Unified Audit Log searches for CopilotInteraction against the affected user set during the gap (Control 1.7).
Increase Communication Compliance review cadence on AI-assisted content from in-scope users (Control 1.10).
Suspend the offending Copilot Studio agent (Control 2.16 agent lifecycle) until its knowledge source is corrected and re-reviewed.
Apply RCD = True on the affected site as a containment action even if RSS is the long-term answer.
Engage eDiscovery hold (Control 1.13 / 1.14) if litigation, examination, or arbitration is foreseeable.

1.5 Pre-escalation checklist (≥ 15 items — complete before opening a Microsoft Support ticket)

1.6 Worked example — confidential legal / M&A memo via mis-scoped surface

Scenario. Compliance reports that a draft policy memo marked Confidential — Legal (alternate scenario: a draft M&A memo containing a non-public counterparty name) appeared as a citation in a Business Chat response for a user who is not on the deal team and should not have access. RCD was applied to /sites/legal-drafts last week.

Triage (first 30 minutes). Severity = SEV-1 candidate (confirmed disclosure of a supervisory / legal record; potential MNPI). Pause: confirm whether the surface was Business Chat (in scope of RCD / RSS) or in-app Copilot inside Word with the file already open (out of RCD scope — see F1). Capture the citation URL, the citation timestamp, the user account, and the tenant cloud. Run Get-SPOSite -Identity https://contoso.sharepoint.com/sites/legal-drafts | Select Url, RestrictContentOrgWideSearch, LockState — confirms RestrictContentOrgWideSearch = True. Run Get-SPOTenantRestrictedSearchAllowedList — site is not on the RSS allow-list. Run a Unified Audit Log search for the user's CopilotInteraction events in a tight UTC window around the citation; export paginated with SHA-256 sidecar.

Root cause path — investigate in this order. (a) Propagation incomplete — rules in if the change is recent and the documented Learn propagation window has not elapsed. (b) F11 — site is also on the RSS allow-list (RSS allow-list contains a site whose RCD is also True; depending on order of evaluation the user may experience apparent inclusion); fix is to remove from one of the two and document. (c) F1 — user invoked Copilot in-app inside Word with the file already open; RCD does not scope the open-document grounding inside an Office app. (d) F6 — file was duplicated to a OneDrive that backs a published declarative agent's knowledge source; the agent grounded on the OneDrive copy, not the SharePoint copy. (e) F4 — a Copilot Studio agent has a direct-URL knowledge source pointing at the legal-drafts site that bypasses the SharePoint connector DLP block.

Containment. Suspend any Copilot Studio agents whose knowledge source includes the site or any related OneDrive (Control 2.16). Tighten DLP-for-Copilot to Block on the relevant sensitive information type / label (Control 1.5). Freeze new Copilot Studio publishes in the affected environment (Control 2.1). Notify Compliance + Legal + Privacy. Start the NY DFS §500.17(a) 72-hour determination clock with Legal if NY-resident NPI or material cybersecurity-event criteria are implicated. Open the Reg S-P §248.30(a)(4) 30-day customer-notification assessment with Legal if customer NPI is implicated. If the memo concerns non-public deal information, notify the firm's MNPI / information-barrier monitor.

Remediation + evidence. Resolve the actual cause path (e.g., remove the site from the RSS allow-list; remove the OneDrive knowledge source; correct the Copilot Studio agent's knowledge source list; verify DLP-for-Copilot block is in effect with a test interaction). Re-test from a non-deal-team user account. Preserve all captures with SHA-256 sidecar in the Control 1.7 evidence bucket. Produce the reportability memo to Compliance and the timeline export to Legal. Update the Zone classification register and the RSS allow-list change log.

§2 — Decision matrix (symptom → likely cause → diagnostic → action → owner)

This matrix covers the dominant grounding-scope failure modes (F1–F16). Use it as a triage map before opening a Microsoft Support case.

#	Symptom (what the user / admin sees)	Likely cause(s)	Deterministic diagnostic	Action	Owner
F1	RCD applied; content still surfaces in in-app Copilot (Word / Excel / PowerPoint / Outlook sidecar)	Scope confusion — RCD governs enterprise grounding / Business Chat; in-app Copilot operates on the open document inside the Office app	Reproduce in Business Chat (cleared cache) vs in-app Copilot; if only in-app, F1 is in scope	Educate users; tighten DLP-for-Copilot (Control 1.5) on the SIT / sensitivity label so the in-app surface is blocked at runtime; apply sensitivity-label encryption to prevent open-document Copilot grounding	AI Governance Lead + Purview Compliance Admin
F2	RSS allowed-list change not in effect after the change was made	Index rebuild / propagation pending — verify the documented Microsoft Learn propagation window at the time of operation (historically observed at 24–48 h; verify current)	Note change UTC; compare to documented window; re-test after the window	Wait the documented window; re-test; do not escalate before window elapses unless a SEV-1 disclosure has occurred	SharePoint Admin
F3	RCD enabled; tenant has no Microsoft 365 Copilot license assigned → control silently no-op	Admin believes the control is enforcing; in fact nothing is being grounded by Copilot at all because no user can invoke it	`Get-MgSubscribedSku \| Where SkuPartNumber -like 'COPILOT' \| Select SkuPartNumber, ConsumedUnits, PrepaidUnits`	Document the no-op state; either license at least one user or remove the false PASS from the control evidence pack; do not assert RCD effectiveness without at least one Copilot-licensed user	Entra Global Admin + AI Governance Lead
F4	DLP blocks the SharePoint connector; maker still ingests the site by adding a direct URL in a Copilot Studio knowledge source	Connector-block ≠ URL-block; need both enforcement vectors	Inventory Copilot Studio knowledge sources per environment; cross-check URLs against the sanctioned connector list	Block at both layers: connector DLP + URL pattern policy; freeze publishes (Control 2.1) until inventory is clean	Power Platform Admin + Purview Compliance Admin
F5	DAG report shows oversharing on a site that is RCD-protected	DAG cadence is delayed; report may pre-date the RCD change; OR RCD was rolled back	Capture DAG report generation timestamp; compare to RCD effective time; re-run DAG and compare	Re-run DAG; if oversharing persists in fresh report, treat as a real RCD failure and follow F1 / F11 path	SharePoint Admin
F6	Personal OneDrive content appears in a declarative agent's grounding	Zone misconfiguration — Zone 1 personal-productivity content path reaching a Zone 2 / Zone 3 agent's knowledge source	Inventory each in-scope agent's knowledge sources; flag any OneDrive personal path	Remove the OneDrive knowledge source; suspend the agent (Control 2.16); update Zone register; cross-reference Controls 4.7, 1.5	Power Platform Admin + AI Governance Lead
F7	RSS 100-site ceiling reached; new site cannot be added	Governance-ceiling event, not a config event; RSS at the ceiling has effectively become a manually curated allow-list	`(Get-SPOTenantRestrictedSearchAllowedList).Count`	Convene RSS allow-list change-control board; document add / remove with business case ledger; do not "make room" without governance approval	SharePoint Admin + AI Governance Lead
F8	Copilot Studio knowledge-source change not visible	Sync window — verify current sync window on Microsoft Learn	Note change UTC; re-test after documented window	Wait documented window; re-test; do not escalate before window elapses	Power Platform Admin
F9	Sovereign cloud (GCC / GCC High / DoD): RCD / RSS / SAM / DAG / DLP-for-Copilot not at parity with Commercial	Operations fail silently with no portal warning	Re-confirm capability at https://learn.microsoft.com cloud parity matrix at time of operation	Document parity gap and apply fallback per §4; flag the affected control evidence as "operating with documented parity exception"	AI Governance Lead + SharePoint Admin
F10	Modern pages indexed; classic ASPX pages on the same site still leak	Modern and classic pages flow through different indexing paths; site appears RCD-protected but classic content leaks	Enumerate site page library; classify modern vs classic	Convert classic to modern OR explicitly scope classic page content out via permissions / archive	SharePoint Admin
F11	RSS allow-list contains a site whose RCD is also `True`	Conflicting scopes; depending on order of evaluation user may experience apparent inclusion or apparent zero results	`Get-SPOTenantRestrictedSearchAllowedList` cross-joined with `Get-SPOSite ... \| Select RestrictContentOrgWideSearch`	Decide the intended state; remove the site from one of the two; document the decision in the RSS change log	SharePoint Admin
F12	`CopilotReady` (or any custom) property bag value not persisting	PnP module stale; site read-only / archive; site collection admin missing	`Update-Module PnP.PowerShell`; check `Get-SPOSite ... \| Select LockState, Status`; verify SCA on the site	Update PnP; resolve site state; re-add SCA; retry idempotently	SharePoint Admin
F13	Bulk `Set-SPOSite -RestrictContentOrgWideSearch $true` partial failure	Throttling; locked sites; archive state — needs an idempotent retry pattern, not a one-shot loop	Re-run with per-site try / catch; collect failures; verify by re-querying every site	Implement idempotent retry with exponential backoff; produce a per-site PASS / FAIL report and remediate failures individually	SharePoint Admin
F14	Guest / external user appears to inherit broader grounding than internal users	RCD does not change SharePoint permissions; B2B + grounding interaction surfaces what the guest already had access to	Audit the guest's effective SharePoint permissions; cross-reference Control 4.4 external sharing posture	Tighten SharePoint sharing posture; re-evaluate guest access model; do not treat as an RCD failure unless permissions are correct and grounding still leaks	SharePoint Admin + Entra Global Admin
F15	Restricted-AU (Administrative Unit) admin attempting an RCD / RSS change and receiving an unexpected error	Some SPO admin surfaces do not honor AU scoping; the operating admin needs tenant scope	Confirm admin role assignment scope; reproduce as a tenant-scoped SharePoint Admin	Use a tenant-scoped admin; document the AU limitation in the runbook	Entra Global Admin + SharePoint Admin
F16	Audit evidence of the RCD / RSS change cannot be produced for an examiner	Audit retention insufficient OR event-type filter incorrect OR the event was never written	Re-run UAL search with the documented event-type list; check retention setting per Control 1.7	Extend retention; engage Microsoft Support if events are missing; document the gap in the Compliance file	Compliance Officer + Purview Compliance Admin

§3 — Anti-pattern catalog

#	Anti-pattern	Why it is wrong / risk
A1	Marking RCD as enforcing because it was set last week, without re-running the deterministic check today	Propagation, license absence (F3), or RSS conflict (F11) can leave the control no-op; control evidence becomes false PASS
A2	Treating an empty `Get-SPOTenantRestrictedSearchAllowedList` as "RSS not in effect"	Silent-zero-row trap; confirm `Get-SPOTenant.EnableRestrictedSearchAllList` first
A3	Blocking only the SharePoint connector via DLP-for-Copilot	F4 — makers add the site via direct URL in Copilot Studio knowledge sources; both enforcement vectors are required
A4	Using Commercial portal URLs (e.g., `purview.microsoft.com`) on a `.us` (GCC High / DoD) tenant	Wrong scope; misleads the admin into believing a feature is missing when it is the wrong portal
A5	Asserting RCD effectiveness without first verifying that any user has a Microsoft 365 Copilot license	F3 — RCD without Copilot is a no-op; admin gets a false PASS
A6	Diagnosing "RCD did not work" without distinguishing Business Chat from in-app Copilot	F1 — RCD does not scope the open-document grounding inside Word / Excel / PowerPoint
A7	Treating the DAG report as real-time	F5 — DAG cadence is delayed; check the report generation timestamp before declaring a real failure
A8	Removing a low-traffic RSS allow-list entry without governance approval to make room for a new one	RSS allow-list is a regulated-scope decision (FINRA 3110 / 25-07 supervisory surface), not a housekeeping decision
A9	Adding a Copilot Studio knowledge source pointing at a personal OneDrive	F6 — Zone leak; the agent inherits a personal-productivity grounding scope and exits the firm's controlled grounding plane
A10	One-shot `Set-SPOSite ... -RestrictContentOrgWideSearch $true` against many sites with no retry / idempotence	F13 — partial failure leaves a half-protected estate that audits as PASS at the policy level
A11	Operating RCD / RSS / DAG / DLP-for-Copilot in GCC High or DoD without documenting parity gaps	F9 — features fail silently with no portal warning; sovereign-cloud evidence pack is incomplete
A12	Closing an incident before producing the audit-evidenced timeline of the RCD / RSS change	FINRA 4511 / SEC 17a-4(f) books-and-records integrity gap; examiner cannot reconstruct the change
A13	Using `$variable -eq $null` instead of `$null -eq $variable` in PowerShell detection scripts	PowerShell idiom; comparison against a collection on the left side returns the filtered collection rather than `$true` / `$false` and produces silent false negatives
A14	Treating Restricted SharePoint Search as a security boundary	RSS is a scope mechanism, not a security boundary. Recent-interaction, sharing, and ownership carve-outs are by design; permissions and DLP remain the security plane
A15	Re-using a single RSS allow-list across sovereign and Commercial tenants without per-cloud verification	Capability and operational behavior differ per cloud; the same allow-list can produce different effective scope

§4 — Sovereign cloud matrix

The matrix below records the operating posture per cloud. Microsoft cloud-feature parity changes; verify against the Microsoft Learn cloud-parity matrix at the time of operation. Document the verification date in the evidence pack.

Capability	Commercial	GCC	GCC High	DoD	Fallback when not at parity
RCD (`RestrictContentOrgWideSearch` per site)	Available	Verify	Verify per release	Verify per release	Manual site-scoping plus RSS allow-list curation; document exception in evidence pack
RSS (`EnableRestrictedSearchAllList` plus allow-list)	Available	Verify	Verify per release	Verify per release	Manual site-by-site scoping; agent-level knowledge-source allow-listing in Copilot Studio
SharePoint Advanced Management (SAM) features that RCD / RSS depend on	Available	Verify	Verify	Verify	Confirm SAM SKU availability for the cloud; if absent, RCD itself may be unavailable
Data Access Governance (DAG) reports	Available	Verify	Verify	Verify	Manual oversharing review via site-permission export; cross-reference Control 4.8
Copilot Studio knowledge source on SharePoint Online	Available	Varies	Verify per release	Verify per release	Restrict to first-party connectors only; document in environment policy (Control 2.1)
Microsoft 365 Copilot (license SKU)	Available	Varies	Verify per release	Verify per release	If Copilot SKU unavailable for the cloud, RCD / RSS still configurable but a no-op until SKU lands; record as documented exception
DLP-for-Copilot location	Available	Verify	Verify	Verify	Tighten upstream DLP on SharePoint and OneDrive locations to compensate
Adaptive Protection / IRM signals into grounding-scope decisions	Available	Verify	Typically not available	Typically not available	Static scoping; periodic manual review per Control 1.6 cadence

Operating any of the above in GCC High or DoD without confirming current parity creates a silent-failure surface. Document the parity verification date and the operating posture in the evidence pack. Where a capability is unavailable, record the fallback explicitly so an examiner can reconstruct the firm's compensating posture.

§5 — Escalation L1 → L4

Response windows below are firm-defined sample targets, not Microsoft commitments. Microsoft does not publish per-incident SLAs for grounding-scope misconfiguration. Tune to your firm's IR runbook.

L1 — SharePoint Admin (operational triage)

Preserve evidence per §1.3 before any remediation.
Run the §1.5 pre-escalation checklist (≥ 15 items).
Apply §1.4 compensating controls; do not leave the gap open.
For SEV-3 / SEV-4 issues, attempt resolution at L1 and document.
Sample target: acknowledge SEV-1 / SEV-2 within 1 h; resolve SEV-3 within 1 business day (firm-defined).

L2 — AI Governance Lead + Power Platform Admin + Purview Compliance Admin

Triage cross-control impact: Controls 1.5 (DLP-for-Copilot), 1.6 (DSPM for AI), 1.7 (audit backbone), 2.1 (environment governance), 2.16 (agent lifecycle), 4.1 (sensitivity labels in SPO), 4.7 (Copilot data governance), 4.8 (item-level permission scanning).
Inventory all Copilot Studio knowledge sources in the affected environment; quarantine any unsanctioned source.
Confirm Zone classification register entries for the affected sites and agents (per Control 2.1).
Coordinate with SharePoint Admin on RCD / RSS state and bulk remediation idempotency (F13).
Sample target: SEV-1 within 1 h; SEV-2 within 4 h.

L3 — CISO + Compliance Officer + General Counsel + Privacy Officer

Reportability determination per the §1.2 decision tree. Legal owns the determination.
NY DFS 23 NYCRR 500 §500.17(a) 72-hour clock evaluation — clock starts at determination, not first alert.
SEC Regulation S-P §248.30(a)(4) customer-notification assessment if customer NPI is implicated.
FINRA Rule 4530 disclosure assessment if firm misconduct is implicated.
Coordinate with HR on any insider-misconduct angle (Control 1.12 IRM cross-reference).
Decide the regulator-notification path (FINRA / SEC / NY DFS / state AGs / OCC / Federal Reserve / CFTC / state-level) — Compliance and Legal own this decision, not Engineering.
Sample target: SEV-1 within 1 h.

L4 — Microsoft Support ticket

Open a Microsoft Support ticket only after L1, L2, and L3 are engaged. Use the §7 payload template. Attach the evidence pack reference (do not attach raw evidence to the ticket without a redaction review). For any artifact containing customer NPI / MNPI, share out of band under NDA.

L5 — Internal Compliance / Legal / HR communication

Use the §7 internal communication template alongside the L4 Microsoft ticket. The internal communication is the official intake into the firm's compliance file and the basis for the regulator-notification posture.

§6 — Detailed failure modes

For each failure mode below: symptom, likely cause, deterministic diagnostic (PowerShell / Graph / portal path), fix, verification, and Microsoft Learn references.

F1 — RCD applied; content still surfaces in in-app Copilot

Symptom. A site is RCD-protected; users invoking Business Chat see no content from the site. Users invoking Copilot inside Word / Excel / PowerPoint / Outlook with a file from the site already open continue to see Copilot summarize / answer over that document.

Likely cause. Scope confusion. RCD scopes enterprise grounding (Business Chat / agent grounding). It does not prevent Copilot in an Office app from operating on the open document the user already has access to.

Diagnostic.

# Confirm RCD state on the site
Get-SPOSite -Identity 'https://contoso.sharepoint.com/sites/legal-drafts' |
    Select Url, RestrictContentOrgWideSearch
# Reproduce in Business Chat with cache cleared; reproduce in-app Copilot in Word with the file open
# If only in-app reproduces, F1 is in scope

Fix. Educate users on the surface distinction. Apply sensitivity-label encryption to the document so in-app Copilot cannot operate on it (Microsoft documents that encryption is the enforcement plane for in-app open-document grounding). Tighten DLP-for-Copilot (Control 1.5) on the SIT / label.

Verification. Re-test in-app with an encrypted document from the site; Copilot should be blocked at the runtime DLP layer or by encryption.

Learn. - https://learn.microsoft.com/sharepoint/restricted-content-discovery - https://learn.microsoft.com/microsoft-365-copilot/microsoft-365-copilot-privacy - https://learn.microsoft.com/purview/dlp-microsoft365-copilot-policies-overview

F2 — RSS allowed-list change not in effect

Symptom. A site was added to the RSS allow-list; users still report Copilot does not return content from it (or, after removal, users still see content from a removed site).

Likely cause. Index rebuild and propagation. Verify the documented Microsoft Learn propagation window at the time of operation (historically observed at 24–48 h; verify current).

Diagnostic.

# Confirm RSS is enabled and the allow-list state
Get-SPOTenant | Select EnableRestrictedSearchAllList
Get-SPOTenantRestrictedSearchAllowedList
# Note the UTC time the change was made; compare to documented window

Fix. Wait the documented window and re-test before escalation. If a SEV-1 disclosure has occurred in the meantime, treat per §1.

Verification. Re-test from a clean Business Chat session after the documented window.

Learn. - https://learn.microsoft.com/sharepoint/restricted-sharepoint-search

F3 — RCD enabled but tenant has no Copilot license assigned (silent no-op)

Symptom. Admin asserts RCD is enforcing across the estate. Control evidence file shows PASS. In reality, no user has a Microsoft 365 Copilot license assigned, so Copilot is not grounding on anything regardless of RCD state.

Likely cause. Control evidence collected from configuration state only, not from the runtime / SKU plane.

Diagnostic.

# Confirm Copilot SKU presence and consumption
Connect-MgGraph -Scopes 'Directory.Read.All'
Get-MgSubscribedSku |
    Where SkuPartNumber -like '*COPILOT*' |
    Select SkuPartNumber, ConsumedUnits, @{n='Total';e={$_.PrepaidUnits.Enabled}}

Fix. Either (a) assign at least one Copilot license to a non-production canary user and re-validate RCD effectiveness, or (b) document the no-op state explicitly in the control evidence pack — do not assert RCD effectiveness without at least one Copilot-licensed canary.

Verification. With a Copilot-licensed canary, attempt a Business Chat query expected to be blocked by RCD; confirm zero results / expected scope.

Learn. - https://learn.microsoft.com/microsoft-365-copilot/microsoft-365-copilot-licensing - https://learn.microsoft.com/sharepoint/restricted-content-discovery

F4 — DLP blocks SharePoint connector; maker adds direct URL in Copilot Studio

Symptom. DLP-for-Copilot policy blocks the SharePoint connector for a sensitive label / SIT. A Copilot Studio agent still grounds on a site that should be blocked because the maker added the site as a direct URL knowledge source.

Likely cause. Connector-block ≠ URL-block. Two enforcement vectors are required.

Diagnostic.

# Inventory Copilot Studio knowledge sources per environment via Power Platform Admin Center export
# Cross-check each URL against the sanctioned connector list and the DLP-allowed connector list
# In Power Platform Admin Center: Environments -> select environment -> Copilot Studio -> Knowledge sources

Fix. Block at both layers. Tighten the Copilot Studio environment policy (Control 2.1) to disallow direct-URL knowledge sources for in-scope environments. Add URL pattern blocks to DLP. Freeze publishes (Control 2.1) until the inventory is clean.

Verification. Attempt to publish an agent with a direct-URL knowledge source pointing at a blocked site; the publish should fail.

Learn. - https://learn.microsoft.com/power-platform/admin/wp-data-loss-prevention - https://learn.microsoft.com/microsoft-copilot-studio/security-and-governance - https://learn.microsoft.com/purview/dlp-microsoft365-copilot-policies-overview

Latency note. DLP enforcement messaging in Copilot Studio has shown latency historically. Verify in-tenant by attempting the prohibited operation immediately after policy change and again after the documented Learn propagation window.

F5 — DAG report shows oversharing on RCD-protected site

Symptom. DAG report flags a site as oversharing despite RCD being applied to it.

Likely cause. DAG cadence is delayed. The report may pre-date the RCD change. Alternative: RCD was rolled back (configuration drift).

Diagnostic.

# Capture the DAG report's generation timestamp (visible in the report header / export metadata)
# Compare to the RCD change time on the site
Get-SPOSite -Identity 'https://contoso.sharepoint.com/sites/legal-drafts' |
    Select Url, RestrictContentOrgWideSearch
# Re-run DAG and compare

Fix. Re-run DAG. If the fresh report still shows oversharing, treat as a real RCD failure and follow the F1 / F11 / F4 path. If the fresh report is clean, the prior result was stale; document and close.

Verification. Two consecutive DAG runs after the RCD change show no oversharing.

Learn. - https://learn.microsoft.com/sharepoint/data-access-governance-reports

F6 — Personal OneDrive content in declarative agent

Symptom. A published Copilot Studio declarative agent surfaces content from a user's personal OneDrive in its responses.

Likely cause. Zone misconfiguration. Zone 1 personal-productivity content reached a Zone 2 / Zone 3 agent's knowledge source, by direct knowledge-source addition or by a connector-driven duplication path.

Diagnostic. Inventory each in-scope agent's knowledge sources. Flag any path under https://<tenant>-my.sharepoint.com/personal/... or any OneDrive URL.

Fix. Remove the OneDrive knowledge source. Suspend the agent (Control 2.16) until the publisher re-asserts a sanctioned knowledge-source posture. Update the Zone register (Control 2.1). Cross-reference Controls 4.7 and 1.5.

Verification. Re-test the agent; confirm no OneDrive citations.

Learn. - https://learn.microsoft.com/microsoft-copilot-studio/knowledge-overview - https://learn.microsoft.com/microsoft-365-copilot/microsoft-365-copilot-privacy

F7 — RSS 100-site ceiling reached

Symptom. Add-SPOTenantRestrictedSearchAllowedListSites fails. Inventory shows 100 sites already on the allow-list.

Likely cause. The RSS allow-list ceiling has been reached. This is a governance event — at the ceiling, the firm has effectively converted Copilot grounding into a manually curated allow-list that requires a documented add / remove flow.

Diagnostic.

$count = (Get-SPOTenantRestrictedSearchAllowedList).Count
"Current allowed sites: $count / 100"

Fix. Convene the RSS allow-list change-control board (AI Governance Lead + SharePoint Admin + Compliance Officer + business-line representative). For each candidate site, document the business case in the RSS change ledger. Removals require the same ledger entry and a justification. Do not "make room" by removing low-traffic entries without governance approval — that violates A8.

Verification. RSS change ledger shows a documented add / remove pair for any net-zero churn. New site is on the allow-list and the displaced site is documented.

Learn. - https://learn.microsoft.com/sharepoint/restricted-sharepoint-search

F8 — Copilot Studio knowledge source change not visible

Symptom. Maker adds, removes, or modifies a knowledge source in Copilot Studio; the change does not appear to take effect when an agent is invoked.

Likely cause. Sync / cache propagation. Verify the current Microsoft Learn-stated sync window at the time of operation.

Diagnostic. Note the change UTC. Re-test after the documented window.

Fix. Wait the documented window. Re-test. Do not escalate before the window elapses unless a SEV-1 disclosure has occurred.

Verification. Agent invocation reflects the new knowledge-source posture.

Learn. - https://learn.microsoft.com/microsoft-copilot-studio/knowledge-overview

F9 — Sovereign cloud parity gap

Symptom. A capability that operates in Commercial does not behave the same way (or is unavailable) in GCC, GCC High, or DoD.

Likely cause. Cloud-feature parity gap. Microsoft does not publish a single SLA for parity; capabilities land at different times in sovereign clouds.

Diagnostic. Re-confirm the capability against the Microsoft Learn cloud-parity matrix at the time of operation. Do not rely on cached parity assumptions older than the operating quarter.

Fix. Apply the §4 fallback for the affected capability. Document the parity verification date and the operating posture in the evidence pack.

Verification. Evidence pack contains the parity verification date, the cloud, and the fallback posture.

Learn. - https://learn.microsoft.com/microsoft-365/enterprise/microsoft-365-us-government-gcc-high - https://learn.microsoft.com/microsoft-365/enterprise/microsoft-365-us-government-dod

F10 — Modern indexed; classic ASPX not

Symptom. A site is RCD-protected and the modern pages are correctly excluded from grounding; classic ASPX page content from the same site continues to surface.

Likely cause. Modern and classic pages flow through different indexing paths. The site appears RCD-protected but classic content can reach grounding via a different code path.

Diagnostic. Enumerate the site's page library and classify modern vs classic.

Fix. Convert classic pages to modern, OR explicitly scope classic page content out via permissions / archive, OR remove classic page content from the site.

Verification. Re-test grounding from a non-privileged user; classic content no longer appears.

Learn. - https://learn.microsoft.com/sharepoint/dev/transform/modernize-classic-pages - https://learn.microsoft.com/sharepoint/restricted-content-discovery

F11 — Site is on RSS allow-list AND has RCD = `True`

Symptom. A site appears on the RSS allow-list but returns no content (or appears to return content despite RCD = True). Conflicting scopes.

Likely cause. RCD and RSS are evaluating against the same site with conflicting intent.

Diagnostic.

$allowList = Get-SPOTenantRestrictedSearchAllowedList
$site = 'https://contoso.sharepoint.com/sites/legal-drafts'
"$site on RSS allow-list: $($allowList -contains $site)"
Get-SPOSite -Identity $site | Select Url, RestrictContentOrgWideSearch

Fix. Decide the intended state. Remove the site from one of the two scopes. Document the decision in the RSS change log and the RCD evidence pack so an examiner can reconstruct the intent.

Verification. After remediation, the site appears in exactly one of (RSS allow-list, RCD-protected) and Business Chat behavior matches the intent.

Learn. - https://learn.microsoft.com/sharepoint/restricted-content-discovery - https://learn.microsoft.com/sharepoint/restricted-sharepoint-search

F12 — Property bag value not persisting

Symptom. PnP-based property-bag writes (e.g., CopilotReady = True) do not persist on the site.

Likely cause. PnP module stale; site read-only / archive; site-collection admin missing on the operating account.

Diagnostic.

Update-Module -Name PnP.PowerShell
Get-SPOSite -Identity $siteUrl | Select Url, LockState, Status
# Add SCA if missing
Set-SPOUser -Site $siteUrl -LoginName <admin-upn> -IsSiteCollectionAdmin $true

Fix. Update PnP. Resolve site state (unlock, restore from archive). Re-add SCA. Retry idempotently.

Verification. Get-PnPPropertyBag returns the expected value after re-connect.

Learn. - https://learn.microsoft.com/powershell/sharepoint/sharepoint-pnp/sharepoint-pnp-cmdlets

F13 — Bulk `Set-SPOSite` partial failure

Symptom. A bulk operation to apply RCD across many sites reports success in the orchestrator log but spot-checks reveal that some sites did not receive the change. Audits at the policy level show PASS while a subset of sites is unprotected.

Likely cause. Throttling, locked sites, archived sites, or transient errors in a one-shot loop with no retry.

Diagnostic.

# After the bulk run, re-query every site individually and produce a PASS / FAIL report
$sites = Get-SPOSite -Limit All
$report = $sites | ForEach-Object {
    [pscustomobject]@{
        Url = $_.Url
        RCD = $_.RestrictContentOrgWideSearch
        LockState = $_.LockState
        Status = $_.Status
    }
}
$report | Where { -not $_.RCD } | Export-Csv -Path .\rcd-misses.csv -NoTypeInformation

Fix. Implement an idempotent retry pattern with exponential backoff and per-site try / catch. Re-apply RCD to the failures individually. Do not declare the bulk operation complete until the per-site verification report is clean.

Verification. Per-site verification report shows zero misses across the in-scope estate.

Learn. - https://learn.microsoft.com/sharepoint/restricted-content-discovery - https://learn.microsoft.com/powershell/sharepoint/sharepoint-online/connect-sharepoint-online

F14 — Guest / external user inherits broader grounding than internal users

Symptom. A B2B guest user appears to surface content via Copilot grounding that internal users do not see, OR a guest sees content they should not.

Likely cause. RCD does not change SharePoint permissions. The guest's effective permissions are the security plane; grounding inherits from permissions.

Diagnostic. Audit the guest's effective SharePoint permissions on the affected sites. Cross-reference Control 4.4 external sharing posture and Control 4.8 item-level permission scanning.

Fix. Tighten SharePoint sharing posture. Re-evaluate the guest access model. Do not treat as an RCD failure unless permissions are correct and grounding still leaks.

Verification. With permissions corrected, the guest's grounding matches the intended scope.

Learn. - https://learn.microsoft.com/sharepoint/external-sharing-overview

F15 — Restricted Administrative Unit admin attempting RCD / RSS change

Symptom. An admin assigned to an Administrative Unit (AU) cannot complete an RCD / RSS change and receives an unexpected error or no-op.

Likely cause. Some SharePoint admin surfaces do not honor AU scoping. The operation requires a tenant-scoped admin role.

Diagnostic. Confirm the operating admin's role assignment scope (AU vs tenant). Reproduce the operation as a tenant-scoped SharePoint Admin.

Fix. Use a tenant-scoped admin for RCD / RSS operations. Document the AU limitation in the runbook so it is not re-discovered each time.

Verification. Operation completes as tenant-scoped admin.

Learn. - https://learn.microsoft.com/entra/identity/role-based-access-control/administrative-units

F16 — Audit evidence of RCD / RSS change cannot be produced for examiner

Symptom. During an examination or internal audit, the RCD / RSS change history for a site cannot be produced from the Unified Audit Log.

Likely cause. Audit retention insufficient for the period in question; OR the wrong event-type filter was used; OR the event was never written (a sovereign-cloud or licensing parity gap can mute certain admin-event categories).

Diagnostic. Re-run the UAL search with the documented event-type list current at the time of the change. Check the audit retention setting per Control 1.7. Verify the audit log was enabled at the time of the change.

Fix. Extend retention going forward (Control 1.7). Engage Microsoft Support if events are confirmed missing. Document the gap explicitly in the Compliance file; the gap itself is a books-and-records integrity concern under FINRA 4511 / SEC 17a-4(f).

Verification. The change history for the site is reproducible from UAL within the retention window.

Learn. - https://learn.microsoft.com/purview/audit-solutions-overview - https://learn.microsoft.com/purview/audit-log-retention-policies

§7 — Microsoft Support escalation payload + internal Compliance / Legal communication template

7.1 Microsoft Support ticket payload (paste verbatim; fill bracketed fields)

Severity: [SEV-1 | SEV-2 | SEV-3]
Tenant ID: [GUID]
Cloud: [Commercial | GCC | GCC High | DoD]
Affected workload: Microsoft 365 Copilot grounding scope (RCD / RSS / Copilot Studio knowledge source / DLP-for-Copilot)
Affected feature: [RCD | RSS | SharePoint Advanced Management | DAG | Copilot Studio knowledge source | DLP-for-Copilot | combination]
Affected scope:
  - Site URL(s): [list]
  - Copilot Studio environment(s): [list]
  - Agent(s): [list]
  - User population: [count and characterization, e.g., "1 confirmed disclosure, 200 potentially in scope based on RSS allow-list"]
  - UTC window start - end: [YYYY-MM-DDTHH:MM:SSZ - YYYY-MM-DDTHH:MM:SSZ]
Symptom (one line):
  [e.g., "RCD applied to /sites/legal-drafts on 2026-04-10T14:00Z; site not on RSS allow-list; Business Chat returned a citation from the site to a non-privileged user on 2026-04-17T11:32Z; in-app vs Business Chat surface confirmed (Business Chat); no RCD rollback in audit log; pre-escalation checklist items 1-19 pass."]
Pre-escalation checklist: items 1-19 confirmed PASS (per §1.5 of internal playbook).
Business impact:
  Confirmed / suspected disclosure of [supervisory record | draft regulatory filing | customer NPI | MNPI]; potential FINRA Rule 3110 / 4511 / 25-07 supervisory and books-and-records exposure; NY DFS 23 NYCRR 500 §500.17(a) 72-hour determination clock evaluation: [pending Legal | not applicable | clock running since UTC X]; SEC Reg S-P §248.30(a)(4) customer-notification assessment: [pending Legal | not applicable | active]; firm is in [active examination | quarter-end | none].
RCD / RSS state dump:
  Get-SPOSite output: [attached / inline]
  Get-SPOTenant search/Copilot fields: [attached / inline]
  Get-SPOTenantRestrictedSearchAllowedList: [attached, row count, SHA-256]
  Get-MgSubscribedSku Copilot SKU: [attached]
Copilot Studio knowledge-source inventory: [attached per environment]
Audit-log export: [paginated CSV/JSON, SHA-256 sidecar; DO NOT attach raw NPI; share out of band under NDA]
Evidence pack reference: [internal evidence ID; storage location; offer to share artifacts under NDA]
Steps already taken:
  - Pre-escalation checklist items 1-19 confirmed
  - Compensating controls in place: DLP-for-Copilot tightened to Block on [SIT/label] (Control 1.5); Copilot Studio publish freeze in environment [name] (Control 2.1); offending agent suspended (Control 2.16); daily UAL searches running for affected user set (Control 1.7); Communication Compliance review cadence increased on AI-assisted content (Control 1.10)
Engineer of record: [name, role, email, phone, time zone]
Compliance contact: [name, role, email]
Privacy contact (if NPI in scope): [name, role, email]

7.2 Internal Compliance / Legal / HR / Privacy communication template

To: Compliance Officer; General Counsel; Privacy Officer; CISO; (HR if insider misconduct in scope)
From: [AI Governance Lead]
Severity: [SEV-1 | SEV-2]
Subject: Microsoft 365 Copilot grounding-scope event — [date]

1. What happened
   - [Plain-language description, no jargon]
   - Affected site(s): [list]
   - Affected agent(s) / environment(s): [list]
   - Affected user population: [N users; characterize: registered representatives, RIA staff, external guests, etc.]
   - Surface: [Business Chat | in-app Copilot | Copilot Studio agent | combination]
   - UTC window: [start - end]
   - Confirmed disclosure: [yes / no / under investigation]
   - Content category at risk: [customer NPI | MNPI | supervisory record | draft regulatory filing | restricted-list / watch-list | other]

2. Possible regulatory exposure (§1.2 reportability triage; Legal owns determination)
   - FINRA Rule 3110 supervisory system: [yes / unclear / no]
   - FINRA Notice 25-07 AI / agent supervision: [contextual]
   - FINRA Rule 4511 / SEC 17a-4(f) books-and-records integrity: [yes / unclear / no]
   - GLBA 501(b) / SEC Reg S-P §248.30(a)(4): [if customer NPI in scope; 30-day customer-notification timeline]
   - SOX §302 / §404 ICFR: [if financial-disclosure-adjacent]
   - NY DFS 23 NYCRR 500 §500.17(a) 72-hour cybersecurity-event clock: [pending Legal | not applicable | clock running since UTC X]
   - OCC 2011-12 / Fed SR 11-7 model risk: [if the agent surface itself produced a model-risk-adjacent failure]
   - CFTC Rule 1.31: [if covered swap / trading content]
   - FINRA Rule 4530: [if firm misconduct in scope]

3. Evidence preserved (per §1.3)
   - Site state dumps, tenant state, RSS allow-list export, Copilot SKU inventory, Copilot Studio knowledge-source inventory, paginated UAL export with SHA-256 sidecars, DAG report with generation timestamp, DLP-for-Copilot policy snapshot, Zone register entries, page composition snapshot, parity verification date for sovereign cloud
   - Stored in Control 1.7 evidence bucket reference [ID]

4. Compensating controls in place (per §1.4)
   - DLP-for-Copilot tightened to Block on [SIT/label] (Control 1.5)
   - Copilot Studio publish freeze in environment [name] (Control 2.1)
   - Offending agent suspended (Control 2.16)
   - Daily UAL searches running for affected user set (Control 1.7)
   - Communication Compliance review cadence increased (Control 1.10)
   - eDiscovery hold engaged where litigation / examination is foreseeable (Control 1.13 / 1.14)

5. Open questions for Compliance / Legal / Privacy / HR
   - Reportability determination per §1.2 tree
   - NY DFS 72-hour determination
   - Customer-notification timeline if customer NPI in scope (SEC Reg S-P)
   - Examiner-disclosure obligation if firm is in active examination
   - HR coordination if insider-misconduct angle exists
   - Privacy register update for any pseudonymization / re-identification performed during the incident

6. Next status update: [UTC]

§8 — Cross-references

Control 4.6 — Grounding Scope Governance (parent control)
Control 4.6 portal walkthrough
Control 4.6 PowerShell setup
Control 4.6 verification & testing
Control 4.7 — Microsoft 365 Copilot data governance — troubleshooting (companion control on the SharePoint pillar)
Control 4.8 — Item-level permission scanning of agent knowledge sources — troubleshooting (detects oversharing that grounding inherits)
Control 4.1 — SharePoint sensitivity label deployment — troubleshooting
Control 1.5 — DLP for Microsoft 365 Copilot — troubleshooting (runtime block at the Copilot location)
Control 1.6 — DSPM for AI — troubleshooting (detection plane for AI data exposure)
Control 1.7 — Audit log backbone — troubleshooting (books-and-records evidence backbone)
Control 2.1 — Power Platform environment governance — troubleshooting (publish freeze; environment policy for Copilot Studio)
Control 2.16 — Agent lifecycle and suspension — troubleshooting (suspend offending agents during incident)
AI incident response playbook
Role catalog (canonical role names used throughout)

External (verify URL currency at time of operation): - https://learn.microsoft.com/sharepoint/restricted-content-discovery - https://learn.microsoft.com/sharepoint/restricted-sharepoint-search - https://learn.microsoft.com/sharepoint/advanced-management - https://learn.microsoft.com/sharepoint/data-access-governance-reports - https://learn.microsoft.com/microsoft-365-copilot/microsoft-365-copilot-privacy - https://learn.microsoft.com/microsoft-365-copilot/microsoft-365-copilot-licensing - https://learn.microsoft.com/purview/dlp-microsoft365-copilot-policies-overview - https://learn.microsoft.com/microsoft-copilot-studio/knowledge-overview - https://learn.microsoft.com/microsoft-copilot-studio/security-and-governance - https://learn.microsoft.com/power-platform/admin/wp-data-loss-prevention - https://learn.microsoft.com/purview/audit-solutions-overview - https://learn.microsoft.com/purview/audit-log-retention-policies

Back to Control 4.6 | Portal Walkthrough | PowerShell Setup | Verification & Testing

Updated: April 2026 | Version: v1.4.0 | UI Verification Status: Current

Control 4.6: Grounding Scope Governance — Troubleshooting

§1 — FSI Incident Handling — READ THIS FIRST

1.1 Severity matrix — grounding-scope events

1.2 Reportability decision tree (escalate; do not decide internally)

1.3 Evidence preservation — capture before remediation

1.4 Compensating controls — apply during the gap

1.5 Pre-escalation checklist (≥ 15 items — complete before opening a Microsoft Support ticket)

1.6 Worked example — confidential legal / M&A memo via mis-scoped surface

§2 — Decision matrix (symptom → likely cause → diagnostic → action → owner)

§3 — Anti-pattern catalog

§4 — Sovereign cloud matrix

§5 — Escalation L1 → L4

L1 — SharePoint Admin (operational triage)

L2 — AI Governance Lead + Power Platform Admin + Purview Compliance Admin

L3 — CISO + Compliance Officer + General Counsel + Privacy Officer

L4 — Microsoft Support ticket

L5 — Internal Compliance / Legal / HR communication

§6 — Detailed failure modes

F1 — RCD applied; content still surfaces in in-app Copilot

F2 — RSS allowed-list change not in effect

F3 — RCD enabled but tenant has no Copilot license assigned (silent no-op)

F4 — DLP blocks SharePoint connector; maker adds direct URL in Copilot Studio

F5 — DAG report shows oversharing on RCD-protected site

F6 — Personal OneDrive content in declarative agent

F7 — RSS 100-site ceiling reached

F8 — Copilot Studio knowledge source change not visible

F9 — Sovereign cloud parity gap

F10 — Modern indexed; classic ASPX not

F11 — Site is on RSS allow-list AND has RCD = True

F12 — Property bag value not persisting

F13 — Bulk Set-SPOSite partial failure

F14 — Guest / external user inherits broader grounding than internal users

F15 — Restricted Administrative Unit admin attempting RCD / RSS change

F16 — Audit evidence of RCD / RSS change cannot be produced for examiner

§7 — Microsoft Support escalation payload + internal Compliance / Legal communication template

7.1 Microsoft Support ticket payload (paste verbatim; fill bracketed fields)

7.2 Internal Compliance / Legal / HR / Privacy communication template

§8 — Cross-references

F11 — Site is on RSS allow-list AND has RCD = `True`

F13 — Bulk `Set-SPOSite` partial failure