Does Google NotebookLM / Gemini Notebook sign a BAA?
Only on some plans or setups
Google says Gemini Notebook (formerly NotebookLM) in Google Workspace is not covered by its HIPAA BAA. Google Cloud's BAA list does include 'Gemini Notebook Enterprise', and Google publishes no BAA for the consumer version.
Not fully covered by the BAA: Gemini Notebook (Workspace edition): source-grounded chat, audio overviews, notes.
- Business associate
- Tool
- Google NotebookLM / Gemini Notebook
- Plans with a BAA
- Gemini Notebook Enterprise (Google Cloud)
- Checked
By plan
| Plan | BAA | How to get it | Conditions |
|---|---|---|---|
| Gemini Notebook in Google Workspace | No BAA | Not offered | The Workspace privacy hub says Gemini Notebook is not covered by Google's BAA. It is also missing from the Workspace covered-services list, even though a Workspace BAA (accepted in the Admin console) covers Gemini in Workspace and the Gemini app.[1],[2],[3] |
| Gemini Notebook Enterprise (Google Cloud) | Signs a BAA | Accept or sign online | Listed among Google Cloud services covered by the Google Cloud BAA, which customers review and accept through Google Cloud's privacy compliance settings.[2] |
| Consumer NotebookLM (personal Google accounts, incl. Google AI plans) | Not confirmed | Not stated | No Google page reviewed covers BAAs for personal accounts. Google's BAA lists cover Google Cloud and Workspace services only.[2] |
Are the AI features covered?
Vendors often sign a BAA for the core product but leave some AI features out. Here is what Google says about each one.
| AI feature | Under the BAA | Details |
|---|---|---|
| Gemini Notebook (Workspace edition): source-grounded chat, audio overviews, notesGemini Notebook in Google Workspace | Excluded | Not covered by Google's BAA, and Google says it does not yet hold the related certifications.[1] |
| Gemini Notebook EnterpriseGemini Notebook Enterprise (Google Cloud) | Covered | Listed on the Google Cloud BAA services list with no exclusion note.[2] |
Workspace and collaboration AI that offer a BAA
- Adobe Acrobat AI AssistantBAA on: Acrobat Studio for enterprise: Analyzer in Acrobat, Acrobat Studio for enterprise: Knowledge Base in AcrobatSome plans only
- Airtable AIBAA on: Enterprise ScaleSome plans only
- Asana AIBAA on: AsanaGov, Enterprise+Some plans only
- Atlassian Rovo / Atlassian Intelligence (Confluence, Jira)BAA on: Enterprise, Standard / Premium (Jira, Jira Service Management, Jira Product Discovery, Confluence)Some plans only
- Box AIBAA on: Enterprise / Enterprise Plus / Enterprise AdvancedSome plans only
- ClickUp BrainBAA on: EnterpriseSome plans only
All BAA-ready alternatives to Google NotebookLM / Gemini Notebook
Sources
- Generative AI in Google Workspace Privacy Hub
- HIPAA compliance on Google Cloud and Google Workspace
- HIPAA Compliance with Google Workspace and Cloud Identity
A signed BAA is necessary but not sufficient for HIPAA compliance, which also depends on configuration, access controls, and your own policies. Verdicts summarize the vendor's own published terms as of the date checked; confirm with the vendor and your counsel before sending protected health information. Not legal advice.