Can an AI assistant run inside your own cloud account?
Three places a practice’s AI assistant can run, worth comparing: a vendor’s app, your Google Workspace, or a cloud account your practice owns. For each, the agreement you need, from the providers’ own pages.
When a practice asks where an AI assistant can run, three shapes are worth comparing. They differ in which agreement you need, whose account the assistant lives in, and how much of the setup is yours.
A vendor’s own app
You sign up with the AI company and your staff use its app. The patient information sits in the vendor’s systems, so the agreement has to be with that vendor and has to name the product. OpenAI’s guide says its consumer plans and ChatGPT Business are not Eligible Services, and that its ChatGPT section applies to the products the BAA names.
The AI built into Google Workspace
If your practice already runs on Google Workspace, check here first. Google says customers who have not signed a BAA with Google “must not use PHI in Google Workspace or Cloud Identity services,” that administrators must review and accept a BAA before using patient information, and that the agreement is made available for electronic acceptance in the Admin console. (Google’s Workspace page calls it a Business Associate Amendment.)
Google’s HIPAA page for Google Cloud lists Gemini among the Google Workspace services its BAA includes: “Gemini App (excluding Gemini in Google Chrome)” and “Gemini in Google Workspace,” on a list dated August 31, 2025. Google’s Workspace page says third-party applications, including add-ons, are not included in the functionality its BAA covers, and it points to its own “HIPAA Included Functionality” list for the products that can be used. Check that the specific feature you want is on Google’s current list before you rely on it; the list is Google’s to change.
An assistant installed in a cloud account you own
The third shape puts the assistant inside a cloud account that belongs to the practice. The practice accepts the cloud provider’s BAA for that account, and the assistant and what it knows live there. Google’s page says the Google Cloud BAA includes “the entire Google Cloud infrastructure” and lists products, among them Gemini Enterprise Agent Platform and Generative AI on Agent Platform, on a list dated September 17, 2025. The same page says to disable unsupported services when working with patient information and not to use pre-GA offerings with it unless a notice or the offering’s own terms say otherwise.
This is the shape we offer. We set up an assistant inside the practice’s own cloud account, load it with the practice’s policies and procedures, and hand it over with working sessions for your staff and a written operating guide. We deliver it on Google Cloud today; AWS and Azure are available on request. What the assistant knows and writes is kept as ordinary files in that account, so the practice can copy all of it out whenever it likes, with standard cloud tools and without asking us.
It takes more setup than switching on a feature in a tool you already use, and it adds a monthly cloud bill in your own account, which we estimate for you before you commit.
Four questions to ask
- Whose account is it? In a vendor’s app, your data sits in the vendor’s systems. In a cloud account you own, you administer the account, and the cloud provider still holds the data under its BAA with you.
- Which agreement names the service, and what does it leave out?
- Can we copy out everything the assistant knows and writes, with tools we control and without asking permission?
- Which features are covered today? Providers change their lists, so read the current page rather than last year’s summary.
This is general information, not legal advice. Ask your own counsel about your practice.
Where this comes from
Each passage in quotation marks is copied from one of these pages as we read it on October 23, 2026. Providers change their pages, so open the current version before you rely on a passage.
See what an install in your own cloud account includes.
One fixed price covers the installation, the knowledge setup and the handover. Your own monthly cloud bill and the business associate agreements you sign are not included.