Google Calendar is HIPAA compliant for entering, receiving, storing, or sharing Protected Health Information when it is used as part of a business Google Workspace account that is configured to comply with HIPAA and covered by the HIPAA Business Associate Addendum to Google’s Service Agreement.
Google Calendar is a time management and calendar scheduling service within Google Workspace. Healthcare organizations may use the service to schedule appointments and coordinate care activities, which can result in Protected Health Information being included in calendar entries, invitations, or notes. When Protected Health Information is stored in a cloud service, HIPAA conditions for vendor handling of Protected Health Information apply before any disclosure occurs.
Use of Google Calendar with electronic Protected Health Information requires a risk analysis that evaluates risks to confidentiality, integrity, and availability. Identified risks require risk management actions that reduce risk to a level the organization has determined is acceptable. The environment also needs access controls so electronic Protected Health Information can be viewed only by authorized individuals, security controls that reduce the likelihood of unauthorized disclosures, and an audit trail.
HIPAA Covered Entities and Business Associates also need a HIPAA-compliant business associate agreement with any vendor before any electronic Protected Health Information is disclosed, even when a vendor states it does not access customer data or cannot read data because it is encrypted. Google addresses this requirement through a Business Associate Addendum that customers accept as an addendum to its Service Agreement rather than through individualized agreements.
Google’s Business Associate Addendum applies to services with covered functionality, including Google Calendar. Acceptance of the addendum needs to occur before any Protected Health Information is disclosed to Google, including encrypted Protected Health Information. When the account is a business Google Workspace account, configuration supports HIPAA compliance, and the Business Associate Addendum has been accepted, Google Calendar can be treated as a HIPAA compliant calendar scheduling service.
