Google Keep is HIPAA compliant for creating and sharing notes that contain electronic protected health information when a HIPAA Covered Entity or Business Associate subscribes to a Google Workspace plan that supports HIPAA compliance, reviews and accepts Google’s Business Associate Addendum to the Workspace Service Agreement, and configures Google Drive settings and operational controls to prevent unauthorized access or impermissible disclosures.
Google Keep is a note taking application that allows users to create notes on one device and access them on other devices. Notes can include text, voice notes, photos, and files. Notes created in Google Keep are accessed across devices through Google Drive, and Google Drive is part of Google Workspace. HIPAA compliant use depends on the Google Workspace account type, the executed contractual terms, and the configuration of access and sharing controls.
A Business Associate Addendum that covers Google Keep does not, by itself, make an implementation compliant. HIPAA Covered Entities remain responsible for online HIPAA training, role based access decisions, and oversight of how the service is used. Monitoring is required to confirm that Google services are being used as configured and that workflows do not allow electronic protected health information to be exposed through sharing settings or user error. Google Drive is not HIPAA compliant by default, and default settings can permit sharing behaviors that do not align with the HIPAA Privacy Rule or the HIPAA Minimum Necessary Rule.
HIPAA compliant use of Google Keep requires Google Drive access controls and file sharing permissions that prevent notes from being shared outside the organization. Sharing should be limited to individuals authorized to access the electronic protected health information. Access control configuration should align with the HIPAA Security Rule requirements for unique user identification and access authorization practices.
Technical controls and endpoint protections remain part of the compliance boundary. Files stored on Google Drive are encrypted on the server, but files are not encrypted when they are downloaded. Devices used to access or store downloaded content require controls that prevent unauthorized access, with attention to mobile devices that can be lost or stolen. Password protection alone does not meet the control needs described in the source, and administrative controls should account for how workforce members access, store, and transmit downloaded content.
Audit trails are also required for compliant use. Logs should be maintained to support accountability for access and changes involving electronic protected health information. Google’s Business Associate Addendum states that additional services related to Google Drive must be disabled, and administrative configuration should reflect that requirement when Google Keep is used with electronic protected health information.