Azure OpenAI GPT-5.6 Sol Data Zone EUR – HDS compliance and processing locations

We are a French digital health company preparing an Azure OpenAI deployment that may ultimately process personal health data subject to French HDS requirements.

Our Azure OpenAI resource is located in France Central. The deployment uses:

• Model: GPT-5.6 Sol
• Model version: 2026-07-09 (GA)
• Deployment type: Data Zone Standard
• Data zone: EUR

We have reviewed Microsoft’s current HDS Certificate (No. 1042480-3) and the August 2026 HDS Representation of Guarantees available through the Service Trust Portal.

Before processing any real patient data, we need written confirmation from Microsoft of the following:

1. Can GPT-5.6 Sol with Data Zone Standard EUR process prompts or completions in Switzerland North, or in any other location outside the EEA?
2. Are all possible processing locations for this deployment covered by Microsoft’s current HDS certification applicable to Azure?
3. Does HDS Certificate No. 1042480-3 apply to this specific Azure OpenAI / GPT-5.6 Sol / Data Zone Standard EUR architecture?
4. What contractual HDS terms apply to a French Azure customer processing personal health data, and is any additional HDS agreement, addendum, enrollment, or customer configuration required?
5. What is the current retention period for prompts/completions under standard Azure OpenAI abuse monitoring?

We have separately submitted an application for Modified Abuse Monitoring.

Because these questions require confirmation of Microsoft’s internal processing locations and contractual/certification scope, public documentation does not appear sufficient to establish the answer. Please escalate this request to the appropriate Azure OpenAI privacy/compliance team and create a private support case if required.

No patient data is currently being processed through this deployment.