Microsoft OneNote can be used in a HIPAA-compliant manner only when a HIPAA Covered Entity or Business Associate uses it under a Microsoft 365 plan that supports HIPAA compliance, has Microsoft’s HIPAA Business Associate Agreement in place for the in-scope services that store or transmit electronic protected health information, configures those services to meet HIPAA Security Rule safeguards, and enforces workforce policies that control use and disclosure under the HIPAA Privacy Rule and the HIPAA Minimum Necessary Rule.
OneNote is a note-taking application that can store text, images, and files, and it commonly relies on connected cloud storage such as OneDrive and SharePoint when used with Microsoft 365. HIPAA compliance depends on the full workflow around notes that contain protected health information, including storage location, account type, identity controls, sharing settings, audit logging, retention controls, and device management. OneNote used with unmanaged consumer services or personal accounts creates compliance exposure because access controls, audit controls, and administrative oversight are not under the organization’s governance.
Microsoft’s public guidance on its platform has included direct statements about cloud storage and HIPAA use cases, including the Microsoft-hosted Q and A response, “If you store your OneNote files on OneDrive they will be HIPAA compliant.” That statement does not remove the organizational obligations under the HIPAA Security Rule to perform a risk analysis, apply risk management, and implement safeguards that match the organization’s environment and threats.
Microsoft is willing to sign a HIPAA Business Associate Agreement for eligible Microsoft 365 and Office 365 services, and the agreement must be executed or otherwise made effective under Microsoft’s terms before using in-scope services to create, receive, maintain, or transmit electronic protected health information. OneNote content stored in OneDrive for Business or SharePoint requires controls such as unique user identification, strong authentication, role-based access, restricted external sharing, and monitoring of audit logs for inappropriate access and distribution. Workforce training and written procedures must address copying content into unmanaged locations, exporting notebooks, forwarding notes by email, and storing protected health information on unmanaged mobile devices.
OneNote can support regulated documentation and internal collaboration when it is deployed under an appropriate Microsoft 365 environment with a HIPAA Business Associate Agreement in place and when administrative, technical, and operational controls govern the entire lifecycle of protected health information in notes.