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.

Based on 3 sources, all from Google unless marked.

Not fully covered by the BAA: Gemini Notebook (Workspace edition): source-grounded chat, audio overviews, notes.

Business associate
Google
Tool
Google NotebookLM / Gemini Notebook
Plans with a BAA
Gemini Notebook Enterprise (Google Cloud)
Checked
Some plans only
Google signs only for the plans listed.

By plan

PlanBAAHow to get itConditions
Gemini Notebook in Google WorkspaceNo BAANot offeredThe 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 BAAAccept or sign onlineListed 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 confirmedNot statedNo 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 featureUnder the BAADetails
Gemini Notebook (Workspace edition): source-grounded chat, audio overviews, notesGemini Notebook in Google WorkspaceExcludedNot covered by Google's BAA, and Google says it does not yet hold the related certifications.[1]
Gemini Notebook EnterpriseGemini Notebook Enterprise (Google Cloud)CoveredListed on the Google Cloud BAA services list with no exclusion note.[2]

Workspace and collaboration AI that offer a BAA

All BAA-ready alternatives to Google NotebookLM / Gemini Notebook

Sources

  1. Generative AI in Google Workspace Privacy HubGoogle, Help center. Checked Oct 11, 2026.
  2. HIPAA compliance on Google Cloud and Google WorkspaceGoogle Cloud, Documentation. Checked Oct 11, 2026.
  3. HIPAA Compliance with Google Workspace and Cloud IdentityGoogle, Help center. Checked Oct 11, 2026.

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.