My install does not seem to do this. I removed the windows drive when installing Linux on a new drive. Put both drives in and select which one to boot in the bios. Its been that way for about a year and, so far, grub updates have never noticed the windows install nor added to grub.

That’s with bazzite, can’t speak for any other distro as that is the only dual-boot machine I own. Bazzite does mention they do not recommend traditional dual boot with the boot loader and recommend the bios method so maybe they have something changed to avoid that?