In a nutshell
- What is the problem? Microsoft's AI function ‘Recall’ takes screenshots of open applications every five seconds on Windows 11 PCs. This permanent recording violates the GDPR.
- How are users affected? Sensitive data such as passwords, bank details and health information can also be recorded. Anyone who has access to the (unlocked) device – whether hackers or other users – can track activities and information.
- What can users do? Stay with Windows 10 or switch to privacy-friendly systems such as Linux. Disable Recall in Windows 11. Please note: this does not offer complete protection, as updates can reactivate it without the user's consent or knowledge.
- Why is this relevant? Data protection is not an optional feature, but a fundamental right. However, instead of making their products GDPR-compliant, companies such as Microsoft are shifting the responsibility for protecting their own data onto users.
What is it about?
In version 11, Microsoft takes screenshots of all open applications on the computer every five seconds. That's twelve times per minute – about as often as a person blinks. This is made possible by the ‘Recall’ feature. The AI-powered software remembers what has been opened, read, searched for and typed. Recall can also store account information, health information and passwords.
By endlessly storing all kinds of information, Microsoft is violating the European General Data Protection Regulation (GDPR). This stipulates that only as much data as is necessary for the respective purpose may be collected (data minimisation and purpose limitation) and that the information collected must be protected from unauthorised access (confidentiality). In addition, no personal and intimate information about citizens may be collected if they do not want this. The GDPR is intended to ensure that personal data is not misused, for example for surveillance, identity theft or financial fraud.
The feature has been available in the EU since July 2025. This poses a massive risk for millions of users.
A digital surveillance camera on your own device
Recall remembers all screen activities: the captured images are stored locally on the computer. With the help of AI, the screenshots are ‘translated’ into searchable data, categorised and analysed.
According to Microsoft, the aim is to help users find files, websites and applications they have accessed more easily. In reality, however, this creates a permanent and searchable log, comparable to a digital surveillance camera on your own device.
How are users affected?
Anyone who has access to the unlocked device can view stored activities: it is possible to reconstruct, down to the second, which programmes, websites or documents have been opened in recent months. Whether it's a Google search for job alternatives on your work laptop, sending a confidential email to your therapist, visiting your favourite porn site or chatting with your best friend about your colleague at work: everyone has digital activities that are intimate, require explanation or are easily misunderstood.
Everyone leaves digital traces that should remain confidential. For some groups, however, the damage or danger of disclosure is particularly great: victims of domestic violence, for example, may visit websites that offer support or a way to escape. If the perpetrator has access to the computer, they can track these activities using the recall function and threaten their partner.
Hackers can access information more easily: all they need is access to the recall data, and they can find sensitive information and confidential content collected in one place. Since there is little way to check who can access or has accessed screenshots, these attacks usually go unnoticed. There is also a risk that Microsoft employees can access the data when screen recordings are uploaded to the cloud.
Invisible danger: How Microsoft is breaking its own security promises
When Microsoft introduced the AI feature in 2024, the software was heavily criticised by data protectionists and IT security experts. Microsoft responded by restricting the feature for the EU. To open Recall, Windows now requires a fingerprint or facial scan. However, tests reveal that biometric activation is only required for the initial setup. After that, the four-digit Windows PIN is sufficient to unlock it. Recall is also supposed to recognise sensitive information as such and black it out in a screenshot. In addition, Microsoft has disabled the feature by default in the EU. Users must first activate Recall on their device.
Filtering out sensitive content is sometimes ineffective: tests show that Recall continues to store passwords and bank details if they are not directly next to keywords such as ‘payment information’ or ‘password’. AI only recognises sensitive information if it knows how and where it is stored. However, people store personal data in countless ways. For example, if usernames and passwords are stored in a text or spreadsheet file without comment, Recall does not recognise them as sensitive information. This is especially true since Recall must first capture private information in order to black it out in a subsequent step.
Updates can secretly reactivate Recall: Regular Windows updates usually occur without the user's consent and can overwrite existing settings. Users are not usually notified of these changes. This means that you would have to check regularly to see if Recall has been activated.
It would not be the first time that AI has recorded despite appearing to be inactive. According to Apple employees, Siri, Apple's voice assistant, has recorded and analysed conversations and passed on information to third parties even when it was inactive. One person reported that they were shown advertisements for a specific surgical treatment after discussing it (as they believed) confidentially with their doctor. According to Apple, the system must first be activated for audio recording by pressing a button or saying words such as ‘Hey, Siri’.
When transparency is lacking, trust disappears
Whether Recall has actually stopped recording cannot be verified by outsiders. The source code is secret, and Microsoft does not publish publicly available, independent audit reports that verifiably confirm that a deactivated Recall really does not make any recordings. Microsoft refers to internal tests and an external security review, but without publicly documented results, nothing can be verified.
It is also impossible to verify whether Recall is limited to Copilot+ PCs, as claimed by Microsoft. There are indications that Recall is also integrated into other PCs running the Windows 11 operating system.
The mere availability of this feature – regardless of whether it is enabled or disabled – undermines trust in the operating system. It also shows that Microsoft has no interest in protecting users' data and privacy.
Microsoft has announced free Windows 10 updates for European users until October 2026 – again only after protests from civil society. However, the Recall feature in Windows 11 remains. Even with the extension of Windows 10 updates, it is only a matter of time before Microsoft users have to switch to Windows 11 and accept the Recall feature. However, users have various options for avoiding Recall.
What can Windows users do?
Stay with Windows 10 as long as security updates are provided
Recall is not integrated there. No automated screen recordings are created. Subsequent activation is technically impossible because the function is not part of the system.
Disable Recall in Windows 11
The function remains part of the operating system and can be reactivated through updates. Users cannot verify whether no recordings are actually made when the function is deactivated. This measure can reduce the risk, but does not eliminate it.
Relying on default settings and manufacturer assurances
Without open source code and independent test reports, neither users nor data protection authorities can determine whether Recall remains permanently inactive or whether data is being processed. Disabling the function is not in the company's interest, as additional data can be used for AI training, creating a conflict of interest.
Data protection is not the sole responsibility of citizens
The measures mentioned above can give private individuals limited control over their data and devices. However, as long as Recall remains an integral part of Windows, the risk of surveillance continues to exist. And it is not only individuals who are affected.
Many government agencies and critical infrastructures within the EU continue to rely on Microsoft operating systems. The federal, state and local governments paid Microsoft approximately one billion euros for licences in 2024, according to information provided by the federal government at the request of the Left Party. In hospitals, for example, deeply personal information is collected and stored from thousands of people. Patients must be able to trust that their data will be treated confidentially and that their medical records will be protected accordingly. Recall calls this promise into question.
Finally, decisive enforcement of the law
With the GDPR, we have strong European data protection that has inspired privacy laws around the world. However, data protection supervisory authorities must also enforce these laws consistently. It must be ensured that monitoring functions of this kind are not part of an operating system and that no software (with or without AI elements) is permitted that cannot be integrated and used in a manner that complies with data protection regulations.
Ramak Molavi Vasse’i, Head of Advocacy and Data Protection Expert at the Centre for Digital Rights and Democracy, is calling for action: she is urging the Irish Data Protection Authority to require Microsoft to comply with data protection regulations in Windows 11. Because Microsoft has its European headquarters in Ireland, the Irish authority is responsible for data protection proceedings against the company. At the same time, she is asking the German Federal Data Protection Commissioner Louisa Specht-Riemenschneider to at least issue an official recommendation not to use Windows 11 in public administration.
The Irish authority has confirmed its jurisdiction but has not commented further despite repeated inquiries. Specht-Riemenschneider responded to the digital rights inquiry: “The European data protection supervisory authorities are in dialogue with Microsoft to ensure the data protection-compliant use of Microsoft products in the EU.”
Promoting and establishing digital sovereignty
Beyond enforcing the GDPR, it is essential to break Microsoft's market monopoly and thus the indirect compulsion to use the Windows operating system. Instead of spending millions of euros on licences that violate the GDPR, the government should develop European data protection-compliant solutions. This not only protects citizens' data, but also shifts public investment, digital infrastructure and the resulting value chain to Europe.
Microsoft will continue to overstep data protection boundaries and will only back down in the face of public criticism, if at all.