Is NotebookLM GDPR compliant? What universities should check
NotebookLM, which Google now calls Gemini Notebook, lets users upload sources and ask an AI questions about them. Many universities already have it inside Google Workspace for Education, while staff and students also use it on personal Google accounts. The terms differ sharply between the two. This page sets out what Google documents and what to check.
Short answer
NotebookLM (renamed Gemini Notebook) is provided by Google. For personal accounts in the EEA the controller is Google Ireland Limited; for Workspace for Education customers in most of the EMEA region the contracting entity is Google Cloud EMEA Limited. In Workspace for Education editions it is a Core Service under the Cloud Data Processing Addendum. Google says content there is not reviewed by people or used for training, but Workspace data region settings do not apply. On personal accounts the consumer privacy policy applies and feedback can be reviewed by people. Whether you can use it depends mainly on which account people use and on your Workspace edition and settings.
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What Google documents publicly
All sources were read on 7 October 2026. Google renamed NotebookLM to Gemini Notebook during 2026; most of its pages now use the new name. "Not found publicly" means we did not find it in the sources listed; it does not mean the safeguard does not exist.
| Topic | What the vendor states | Source |
|---|---|---|
| Company and establishment | Documented Personal accounts: Google Ireland Limited is the controller for users in the EEA and Switzerland. Workspace for Education: the Google contracting entity for EMEA (except France, Italy and Poland, which have their own entities) is Google Cloud EMEA Limited, Ireland. | [1], [2], [3] |
| Where data is stored and processed | Plan-dependent Workspace: "Your organization's data region settings don't apply to data processed and cached by Gemini Notebook." Drive files added as sources are copied into Gemini Notebook. Personal accounts: data may be processed outside the user's country. The separate Google Cloud product, Gemini Notebook Enterprise, documents an EU multi-region option. | [4], [5], [1], [12] |
| Data processing agreement | Plan-dependent Workspace: "As a core Workspace service, Gemini Notebook is subject to your organization's Workspace agreement, including the Cloud Data Processing Addendum." Editions where it is only an Additional Service fall under the Google Terms of Service instead. Personal accounts: no DPA; the Google Privacy Policy applies. | [5], [6], [7], [4] |
| Subprocessors | Documented Google publishes a subprocessor list for Workspace Core Services (updated 23 July 2026). It does not list Gemini Notebook separately. | [8] |
| International transfers | Documented Google LLC is an active participant in the EU-US DPF, the UK Extension and the Swiss-US DPF on the official list. The Cloud DPA provides for an alternative transfer solution where adopted and otherwise SCCs. Google also states it relies on SCCs where no adequacy decision applies. | [13], [6], [9] |
| AI model training on customer content | Plan-dependent Workspace: uploads, queries and responses "will not be reviewed by human reviewers, and will not otherwise be used to train generative AI models", including when users give feedback. Personal accounts: content is not used for training unless the user gives feedback; Google may then review the full interaction and keeps feedback for up to three years, disconnected from the account. | [5], [11], [10] |
| Retention and deletion | Plan-dependent Workspace: prompts and responses are "Not retained after session ends"; uploaded files and notebooks follow the Cloud DPA deletion section (deletion within a maximum of 180 days, after a recovery period of up to 30 days at contract end). Personal accounts: no specific period found other than the feedback rule. | [5], [6], [10] |
| Security certifications | Sources disagree The admin help page lists SOC 1, SOC 2, SOC 3, ISO/IEC 27001, 27017, 27018, 27701 and others. The privacy hub (updated 6 October 2026) says "At this stage Gemini Notebook does not support ISO, SOC, or FedRAMP compliance". It is not covered by Google's HIPAA BAA. | [4], [5] |
| Institution and education controls | Documented Core Service in Education Fundamentals, Standard, Plus, the Teaching and Learning add-on and Google AI Pro for Education. Admins can switch it on or off for everyone, by organisational unit or by group. Available to education users of all ages, with some features restricted for under-18s. | [4], [7] |
What this means for a university
Validemic's analysis
Account type decides almost everything. Inside Workspace for Education, NotebookLM is processed under the university's existing Google contract and the Cloud DPA, with Google as processor, no human review and no training. On a personal Google account, Google Ireland is the controller under the consumer privacy policy, and feedback can be reviewed by people. The practical step is to tell staff and students to use their institutional account, and to check that the service is switched on only where you intend.
Data regions. Many European universities chose a Workspace data region for at-rest storage. Google states plainly that this setting does not cover NotebookLM, and that Drive files used as sources are copied. If your institution's approval of Workspace relied on EU data regions, NotebookLM needs its own assessment, or you may limit it to material without personal data.
What personal data is involved. NotebookLM is designed for people to upload their own material: lecture notes, papers, but also interview transcripts, meeting minutes or student submissions. Published papers are rarely personal data; research data and student work often are. Treat it like any other Workspace service that processes the content users put in, and give researchers guidance on special category data.
Certification evidence. Two Google pages, both updated in October 2026, disagree on whether ISO and SOC certifications cover Gemini Notebook. Do not rely on either; ask your Google representative or check the current reports in Google's Compliance Reports Manager.
DPIA and students. Many universities have a DPIA for Workspace for Education; it should be updated to cover generative AI features, including NotebookLM. For students, the per-OU switch and the under-18 feature limits help, but the data region point applies to them too.
Credit where due. For Workspace customers, Google documents the no-training and no-human-review commitments clearly, brings the tool under the existing DPA, and gives admins granular controls. That is a stronger contractual position than most standalone AI tools offer.
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Questions to ask Google before approving it
- Which certifications currently cover Gemini Notebook in Workspace? Your admin help page and privacy hub give different answers.
- When will Workspace data region settings apply to Gemini Notebook data, and where is that data stored and processed today?
- Where are Drive files copied to when added as sources, and are those copies deleted when the original is deleted or the notebook removed?
- Are any subprocessors used for Gemini Notebook that are not on the Workspace Core Services list?
- How are notebooks shared outside the domain controlled, and can admins block external sharing for Gemini Notebook specifically?
- Can we prevent users from signing in to NotebookLM with personal accounts on managed devices?
- Do audit logs record Gemini Notebook activity, so we can respond to access requests and incidents?
- Is there a route to the EU multi-region processing offered for Gemini Notebook Enterprise for Workspace for Education customers?
The EU AI Act angle
Using NotebookLM to summarise and question one's own sources is normally not a high-risk use under the AI Act, Regulation (EU) 2024/1689. Annex III, point 3 lists the education uses that are high-risk: AI used to decide admission or access, to evaluate learning outcomes, to assess the level of education a person will receive, or to monitor students for prohibited behaviour during tests. A teacher using it to grade student work would bring that use closer to point 3(b) and needs separate thought.
A university that uses an AI system under its authority is a deployer (Article 3(4)). Article 4 on AI literacy has applied since 2 February 2025. Regulation (EU) 2026/1744 (the Digital Omnibus on AI), in force since 27 July 2026, replaced that article: deployers must now "take measures to support the development of AI literacy" of their staff and others using AI on their behalf, without having to guarantee a specific level for each person. The same regulation moved the application date for Annex III high-risk obligations to 2 December 2027.
Obligations for general-purpose AI models (Article 53, applying since 2 August 2025), such as the Gemini models behind NotebookLM, fall on the model provider, Google, not on the university.
Sources
- Google Privacy Policy (effective 1 October 2026), retrieved 7 October 2026
- Google Workspace for Education Terms of Service, retrieved 7 October 2026
- Google Cloud, "Google Entity" contracting entities, retrieved 7 October 2026
- Google Workspace Admin Help, "Turn Gemini Notebook on or off for users" (updated 6 October 2026), retrieved 7 October 2026
- Google Workspace, "Generative AI in Google Workspace Privacy Hub" (updated 6 October 2026), retrieved 7 October 2026
- Google, Cloud Data Processing Addendum (Customers) (last modified 8 June 2026), retrieved 7 October 2026
- Google Workspace Services Summary (last modified 31 August 2026), retrieved 7 October 2026
- Google Workspace and Cloud Identity Subprocessors (updated 23 July 2026), retrieved 7 October 2026
- Google, "Legal frameworks for data transfers", retrieved 7 October 2026
- Gemini Notebook Help, "Privacy and Terms of Use in Gemini Notebook", retrieved 7 October 2026
- Gemini Notebook Help, "Report a problem", retrieved 7 October 2026
- Google Cloud documentation, Gemini Enterprise locations, retrieved 7 October 2026
- Data Privacy Framework List, entry "Google LLC" (Mountain View), via the list's search service, retrieved 7 October 2026
- Regulation (EU) 2024/1689 (Artificial Intelligence Act), Articles 3(4), 4, 53, 113 and Annex III, Official Journal text read via the Publications Office, retrieved 7 October 2026
- Regulation (EU) 2026/1744 (Digital Omnibus on AI), Official Journal text read via the Publications Office, retrieved 7 October 2026
About this page
We read Google's privacy policy, Workspace for Education terms, Cloud Data Processing Addendum, Services Summary, subprocessor list, Workspace admin help, the generative AI privacy hub and NotebookLM help pages, and searched the official Data Privacy Framework list, on 7 October 2026. This page describes public documentation only. It is not legal advice and not a verdict on whether NotebookLM complies with the GDPR; that depends on your agreement, your edition, your settings and your use.
If you work at Google and something here is out of date or incomplete, please contact us and we will review it promptly.
Frequently asked questions
Does NotebookLM train on my data?
With a Workspace or Workspace for Education account, Google says uploads, queries and responses are not reviewed by human reviewers and not used to train generative AI models. With a personal Google account, Google says content is not used for training unless you give feedback; feedback may be reviewed by people and is kept for up to three years.
Is NotebookLM covered by our Google Workspace for Education agreement?
Yes, in the editions where it is a Core Service. Google's Services Summary lists Gemini Notebook (formerly NotebookLM) as a Core Service, and its privacy hub says it is subject to the Workspace agreement including the Cloud Data Processing Addendum. Personal Google accounts are not covered.
Does NotebookLM respect Workspace data regions?
No. Google's admin help says the organisation's data region settings do not apply to data processed and cached by Gemini Notebook (checked 7 October 2026).
Can students under 18 use NotebookLM?
In Workspace for Education, Google says it is available to users of all ages, with some features (such as Deep Research and interactive Audio Overviews) unavailable to users under 18. Admins can turn it on or off by organisational unit or group.
Is NotebookLM ISO 27001 or SOC 2 certified?
Google's pages disagree. The admin help page lists certifications including SOC 2 and ISO/IEC 27001, while the Workspace generative AI privacy hub says Gemini Notebook does not support ISO, SOC or FedRAMP compliance at this stage. Ask Google or check the Compliance Reports Manager.