Google Docs can be used in a HIPAA compliant manner to create, receive, maintain, or transmit Protected Health Information only when it is used within an eligible Google Workspace business plan, the service is configured to meet HIPAA Security Rule requirements, and Google’s standard Business Associate Addendum to the service agreement is executed before any Protected Health Information is uploaded, stored, or shared.
Google Docs is an online service that supports creation, editing, and sharing of documents through Google Drive. When Protected Health Information is stored in or transmitted through a cloud service, the cloud service provider is treated as a business associate rather than a conduit, even when the provider does not access the content. The HIPAA Conduit Exception Rule does not apply in most cloud service scenarios, so a business associate agreement is required before the service is used for Protected Health Information.
The free consumer version of Google Docs cannot be used for Protected Health Information. The free service does not include capabilities used to support HIPAA compliance, including controls associated with access management and audit reporting. Google also does not provide its Business Associate Addendum for free services. A covered entity or business associate that places Protected Health Information into a free Google Docs account creates a HIPAA violation.
For regulated use, organizations subscribe to a Google Workspace business plan or cloud identity account that supports the Business Associate Addendum. Google issues a standard addendum and does not sign a covered entity’s custom business associate agreement. Google Docs is covered under the addendum as part of Google Drive. Google’s terms require regulated customers to avoid using Workspace services with Protected Health Information until the addendum is in place. After execution of the addendum, the covered entity or business associate remains responsible for configuring and using the service in compliance with applicable HIPAA requirements.
Technical controls are part of the compliance configuration. Stored data requires encryption, and data requires encryption during uploading and downloading. Google encrypts data in transit using 128 bit or stronger Advanced Encryption Standard and uses encryption for data transmission to the platform and for data movement within and between data centers. Configuration and administration also need to address account authentication, access authorization, and document sharing permissions so that only authorized users can access documents that contain Protected Health Information.
Operational controls reduce disclosure risk created by collaboration features. Documents that contain Protected Health Information must be stored in accounts that are not publicly accessible. Permissions must be set so access is limited to the minimum set of authorized users required for the task. Protected Health Information should be contained within the document content and not placed in the file name, which can be exposed through listings, sharing prompts, and workflow integrations.
Administrative safeguards remain necessary after technical configuration. Workforce members who use Google Docs for care plans, coordination, or other internal workflows need training on access restrictions, sharing controls, and restrictions on downloading and forwarding content. The HIPAA Security Officer oversees implementation and maintenance of safeguards, and each workforce member remains responsible for using collaboration tools in compliance with established policies and procedures.