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Control 3.14: Copilot Pages and Notebooks Retention and Provenance - Portal Walkthrough

Step-by-step governance workflow for inventorying Copilot Pages, OneNote Notebooks, and Loop component storage; scoping retention policies; and capturing branch, embed, and lineage evidence.

Prerequisites

Access Paths

Portal Path Why it matters
Microsoft Purview portal Solutions > Data Lifecycle Management > Retention policies Scopes retention across Loop workspaces, OneDrive, SharePoint, Exchange
Microsoft Purview portal Solutions > Audit Captures Pages branch, Notebook edit, and Loop component lifecycle events
SharePoint Admin Center Sites > Active sites Identifies Notebook and Loop workspace storage locations
Microsoft Loop app Workspaces Validates Pages and Loop component storage in scope

Steps

Step 1: Inventory artifact storage locations

Enumerate Loop workspaces (Pages and Loop components), OneNote Notebooks, and the OneDrive / SharePoint / Exchange locations that host them. Without a complete inventory, retention scoping risks gaps that examiners will identify.

Step 2: Validate retention scope per artifact type

Confirm the tenant retention policy covers Loop workspaces, Notebook storage locations, and the SharePoint sites hosting embedded Loop components. Flat retention is necessary but is not sufficient for branch and embed lineage — see Step 4.

Step 3: Enable lifecycle audit operations

Verify unified audit logging captures Pages branch events (create, branch, edit, delete), Notebook edits, and Loop component lifecycle events (create, embed, edit, delete). These events feed the lineage trail described in Control 3.14.

Step 4: Establish branch-aware and embed-aware lineage capture

For Pages, design the retention process so each branch is preserved as an independent retained item with a recorded link to its parent. For Loop components, capture the host references each time a component is embedded or unembedded so cross-host lineage can be reconstructed.

Confirm Pages, Notebooks, and Loop components can be searched and held under Control 3.11. Validate that holds preserve branched Pages and embedded Loop components, not only the parent location.

Step 6: Schedule periodic attestation

Schedule a quarterly attestation that branch events for in-scope Pages have been captured and that no branch is unaccounted for. The attestation forms the core evidence artifact for the Regulated tier.

FSI Recommendations

Tier Recommendation
Baseline Include all three artifact types in tenant retention policies and enable lifecycle audit operations.
Recommended Apply branch-aware retention for Pages and section-aware scoping for Notebooks used in supervisory or compliance workflows.
Regulated All Recommended controls plus: examiner-ready evidence pack of all in-scope artifact versions for a sampling period, and quarterly attestation of branch and embed lineage completeness.

Next Steps

FSI Copilot Governance Framework v1.4.0 - April 2026 - Back to Control 3.14