Justin McKelvey

Justin McKelvey

Ran snowboard shops. Taught myself to code. Now I build AI that does real work.

• AI for Business • 7 min read •

Is Google Workspace HIPAA Compliant? The BAA, Covered Apps and Setup for a Small Practice (2026)

TL;DR: Yes, with one click and some homework. As of November 2026, Google will sign a HIPAA Business Associate Agreement (BAA) for Google Workspace, and a super admin accepts it in the Admin console under Account settings, then Legal and compliance. It covers only the services on Google's list: Gmail, Drive, Docs, Sheets, Calendar, Meet, Chat, Gemini in Workspace and a few more. Third-party add-ons, Gemini Notebook (formerly NotebookLM) and Gemini in Chrome are outside it. A free Gmail account can't get it at all. The cheapest plan with an Admin console is Business Starter at $7 a user a month on an annual plan.

I get this question from practice owners with 5 to 20 people who already run on Google. They don't want to move to Microsoft. They want to know if what they have is enough. Usually the contract part is easy. The settings part is where practices fall short.

Is Google Workspace HIPAA compliant? What Google actually signs

No software is HIPAA compliant by itself. What a vendor can do is sign a BAA, a contract saying it will protect the patient data (PHI) it handles for you. I explain that idea across the AI tools in HIPAA compliant AI.

Google signs one for Workspace, and you don't need a sales call. A super administrator reviews and accepts it electronically in the Admin console. Google's help page is blunt about the order: "Customers who have not signed a BAA with Google must not use PHI in Google Workspace or Cloud Identity services." The BAA itself takes effect the date you accept it.

Two limits come with it. First, it applies only to the services Google names. The BAA says it does not apply to "any other Google product, service, or feature that is not a Covered Service." Second, Google puts the job of keeping PHI inside those services on you: the customer "will use controls available within the Services" to do it. That second line is what the admin checklist below is for.

Which Google Workspace plans can get the BAA, and what the cheapest one costs

Google's HIPAA help page doesn't list editions. What it requires is a super admin and the Admin console, and every paid business plan has both. A personal @gmail.com account has neither, so it can't get a BAA. Here are the plans as Google's pricing page showed them on November 8, 2026:

Plan Per user, annual plan Month to month Gemini Vault
Free Gmail $0 $0 Consumer app No (and no BAA)
Business Starter $7 $8.40 Gmail only No
Business Standard $14 $16.80 Adds Docs, Sheets, Slides, Drive, Meet, Chat No
Business Plus $22 $26.40 Same as Standard Yes
Enterprise Quote only Quote only Same as Plus Yes

For a 10-person practice that's $70 a month on Starter, $140 on Standard or $220 on Plus with annual billing. Google's pricing page also advertises 50% off for new customers, for the first 20 users and 12 months, starting November 22, 2026. The full plan breakdown is in Google Workspace pricing.

Two notes before you pick. The BAA costs nothing extra on any of these. And Vault, Google's retention and eDiscovery tool, starts at Plus. Google doesn't require Vault for the BAA, but if you need to keep or search email for a set period, Plus is where that lives. Because Google doesn't publish an edition list, check that the BAA shows up under Legal and compliance in your own console before you count on it.

Which Google Workspace services the BAA covers

Google's covered list for Workspace, last updated October 28, 2026:

  • Email and calendar: Gmail, Google Calendar, Google Groups
  • Files: Google Drive, including Docs, Sheets, Slides, Forms, Photos and Vids
  • Talking: Google Meet, Google Chat, Google Voice (managed users only)
  • Notes and tasks: Google Keep, Google Tasks, Google Sites, Google Cloud Search
  • Building: AppSheet, Google Apps Script, Google Workspace Studio
  • AI: Gemini in Google Workspace, the Gemini app (excluding Gemini in Google Chrome) and the Gemini Mac app
  • Admin: Cloud Identity Management, Google Vault (if applicable)

Anything not on that list is outside the BAA, even if it shows up in the same app launcher. Google's help page calls out two groups by name: third-party applications including add-ons, and the "Additional Google Services" that consumer accounts use, like YouTube. Gemini has its own wrinkles, covered in is Gemini HIPAA compliant.

The admin checklist for a 5 to 20 person practice

This is the order I'd work in. Most of it takes an afternoon for one admin.

  1. Accept the BAA. Sign in as a super admin, go to Account settings, then Legal and compliance, and review and accept it. Do this before any patient data goes in.
  2. Turn on 2-Step Verification and enforce it for everyone in the Security section. Practices get breached through one reused password more than anything clever.
  3. Turn off Additional Google Services (YouTube, Blogger and the rest) for staff who handle PHI. The BAA doesn't extend to them.
  4. Lock down Marketplace apps. Set the Google Workspace Marketplace settings so staff can install only apps you've allowed. Every add-on that touches patient data needs its own BAA from its vendor.
  5. Tighten Drive sharing. Google's guidance is to share with specific people rather than "anybody with the link." Turn off link sharing outside your domain, or at least warn on it.
  6. Turn off Gemini Notebook for the PHI group. Admin console, then Generative AI, then Gemini Notebook, then Service status, set Off for that organizational unit. Google says it isn't covered by the BAA.
  7. Set Gemini conversation history to auto-delete. Generative AI, then Gemini for Workspace, then Conversation history and deletion. Google offers 3, 18 or 36 months. Pick what your retention policy says.
  8. Check Google Voice. It's covered for managed users only. If front desk staff text patients from a personal Voice number, that's outside.
  9. Decide on Vault. If you're on Plus, set retention rules for Gmail and Drive. If you're on Starter or Standard and need retention, that's your reason to move up.
  10. Write it down. One page: which Google apps are approved for PHI, which aren't, who the admin is. That page is half of what an auditor asks for.

The traps I see most in small practices

Personal Gmail. The owner started the practice on a personal Gmail address and never moved. There's no Admin console, no BAA, and no fix short of moving to Workspace on the practice domain.

The add-on everyone forgot. A scheduling, e-signature, CRM or form tool connected to Gmail or Drive. Google covers Google Forms. It doesn't cover the third-party add-on that reads your Forms responses.

Gemini Notebook. It's a Google product inside the same account, it's great for summarizing documents, and Google says plainly that it isn't covered by the BAA. Staff will upload a referral packet to it if nobody tells them not to.

Gemini in Chrome. The Gemini app is covered, but Google's list carves out Gemini in Chrome. Same assistant, different place, different answer.

Public Sites and shared links. Google Sites is covered, but a public intake page or a Drive folder shared with "anyone with the link" is still your exposure. The BAA doesn't stop you from publishing PHI.

Google Workspace or Microsoft 365 for a practice?

If you're already on Google, stay. Moving email for a 10-person practice costs more in lost time than the BAA difference is worth. Both vendors cover their core apps and their built-in AI under a BAA. The difference is how you get it: Google needs a super admin to click accept, and Microsoft includes it automatically in the contract you agreed to when you bought. The Microsoft side is in is Copilot HIPAA compliant.

What to do today

Open your Admin console and check one thing: Account settings, then Legal and compliance. If the BAA isn't accepted, nobody should be putting patient names in Gmail or Drive yet. If it is, work down the checklist above, starting with 2-Step Verification and Marketplace apps.

This is a technology explainer, not legal advice. HIPAA turns on your workflows and your risk analysis, so take this list to your compliance counsel. If you want help setting up Workspace and AI tools for a practice without guessing, that's what my AI consulting for healthcare practices is for.

Sources

Free Resource Justin McKelvey

Get the Free AI Content Toolkit

The exact system I use to turn one idea into a month of content: atomization framework, voice template, prompt library, weekly system.

Frequently Asked Questions

Is Google Workspace HIPAA compliant?
It can be used with patient data once a super administrator accepts Google's Business Associate Agreement (BAA) in the Admin console, under Account settings, then Legal and compliance. The BAA only covers the services on Google's HIPAA list, such as Gmail, Drive, Docs, Sheets, Calendar, Meet, Chat and Gemini in Workspace. Google says customers who haven't signed it must not use PHI in Workspace. The settings and policies on your side are still yours.
Which Google Workspace plan do I need for HIPAA?
Google's HIPAA help page doesn't name an edition. The BAA is accepted by a super admin in the Admin console, which every paid business plan has, so Business Starter ($7 a user a month on an annual plan, as of November 2026) is the cheapest plan with that console. Before you buy, open Account settings, then Legal and compliance, in your own console and confirm the BAA is offered there. Business Plus ($22) adds Vault for retention and eDiscovery, which Google doesn't require for the BAA but many practices want.
Is a free Gmail account HIPAA compliant?
No. A personal @gmail.com account has no Admin console, so there's no place to accept Google's BAA and no BAA covering it. Patient email has to run through a Google Workspace account on your practice's domain with the BAA accepted.
Are Google Workspace Marketplace add-ons covered by the BAA?
No. Google's HIPAA page says third-party applications, including add-ons, are not included in the functionality its BAA covers. A scheduling, e-signature or form add-on that touches patient data needs its own BAA with that vendor, or it shouldn't touch PHI.
Is NotebookLM (Gemini Notebook) covered by Google's HIPAA BAA?
No. Google renamed NotebookLM to Gemini Notebook in July 2026, and its Workspace privacy hub says Gemini Notebook is not covered by the Google BAA for HIPAA compliance. It's also missing from Google's covered-services list. Turn it off for staff who handle PHI.
Does signing Google's BAA make my practice HIPAA compliant?
No. The BAA covers Google's obligations for the covered services. Google's BAA says the customer is responsible for using the controls in Workspace to keep PHI inside those services. Two-step verification, sharing rules, which add-ons are allowed, staff training and your risk analysis are still yours.

More on AI for Business

ChatGPT Business vs Plus (2026): Which One a Small Business Should Actually Pay For

ChatGPT Plus vs Business, as of September 2026: Plus is $20 a month for one person and OpenAI may train on your chats unless you opt out; Business is $20 a seat billed annually or $25 monthly, two seats minimum, with no training by default, admin controls, shared projects for groups, and the Company Knowledge plugin. The side-by-side from OpenAI's pages, and three owner scenarios with a verdict each.

7 min

ChatGPT for Customer Service (2026): What Works, What Breaks, and What It Costs a Small Business

ChatGPT for customer service, as of September 2026: it drafts replies, answers policy questions from your own documents, and triages an inbox for $20 to $25 a seat a month on ChatGPT Business. It can't look up an order, issue a refund, or remember a customer unless you connect the system that holds them. The honest capability line, the plan you need, a setup in six steps, the failure modes, and the point where a real agent takes over.

7 min

ChatGPT Pulse (2026): What It Was, Why OpenAI Retired It, and How to Get the Morning Brief for Your Business

ChatGPT Pulse, the daily research cards OpenAI previewed for Pro users in September 2025, was sunset on June 17, 2026 with a 14-day wind-down. What it did, which plans ever had it, why scheduled tasks replaced it, and how an owner rebuilds the morning brief on a Plus or Business seat without handing ChatGPT the wrong things.

7 min

Is Notion HIPAA Compliant? The Enterprise-Only BAA, Notion AI, and What a Practice Pays (2026)

Yes, but only on Notion Enterprise. The BAA itself is free and you switch it on in settings, but Enterprise has no published price, and Business at $20 a seat gets no BAA at all. Beta features and patient communication are excluded. Here's the setup checklist and what Notion AI does with PHI.

5 min
Justin McKelvey, Austin, TX

Written by

Justin McKelvey

I spent 12 years running snowboard and mountain-bike shops in Colorado, then taught myself to code. Since then: 50+ products shipped, Head of Product at a national sports platform, CTO at an AI startup. Now I put AI to work in real businesses in Austin, TX and remote, and write down what actually works.

Work with me

Want more help? Get the free toolkit · Book a strategy call