For clinicians and their compliance people

Why there’s no BAA.

A Business Associate Agreement is a contract with a vendor that handles your clients' health information. Safeclip doesn't receive session audio, transcripts or notes, so under HHS's guidance on software vendors there is nothing for one to cover. Here is the reasoning, where it stops, and what is still yours to do.

Our reading of public HHS guidance, not legal advice. If you have a compliance advisor, show them this page.

What HHS says

HHS answers this question directly in its HIPAA FAQ. A software company becomes a business associate when it has access to your clients' information, not because you use its software.

“The mere selling or providing of software to a covered entity does not give rise to a business associate relationship if the vendor does not have access to the protected health information of the covered entity. If the vendor does need access to the protected health information of the covered entity in order to provide its service, the vendor would be a business associate of the covered entity.”

HHS, Is a software vendor a business associate of a covered entity? (last reviewed December 28, 2022; archived copy)

“For example, a software company that hosts the software containing patient information on its own server or accesses patient information when troubleshooting the software function, is a business associate of a covered entity.”

HHS, Is a software vendor a business associate of a covered entity? (last reviewed December 28, 2022; archived copy)

Encryption alone doesn't get a cloud tool out of a BAA. HHS's cloud guidance says a cloud service provider (CSP) that stores health information is a business associate even when it can't read it:

“CSPs that provide cloud services to a covered entity or business associate that involve creating, receiving, or maintaining (e.g., to process and/or store) electronic protected health information (ePHI) meet the definition of a business associate, even if the CSP cannot view the ePHI because it is encrypted and the CSP does not have the decryption key.”

HHS, Guidance on HIPAA & Cloud Computing (last reviewed December 23, 2022; archived copy)

That is why cloud scribes sign BAAs: they host the recording or the note. Safeclip doesn't host either.

How Safeclip fits

  • Recording, transcription (Whisper) and the session summary (a local language model) run on your computer. The files are saved there.
  • Session audio and notes stay on your computer. They are not sent to Safeclip. Safeclip's servers have no endpoint that accepts recordings, transcripts or notes.
  • The app's window is locked by a content security policy to the hosts on our published list, so it can't quietly talk to anyone else.
  • What does reach Safeclip is listed, line by line: update checks, feedback you choose to send, and if you sign in for Founding, your email, your license and a daily license check. None of it is session content. What leaves your computer →
  • Support doesn't need your library to help you, so we won't ask to see client data or share your screen while it's open. HHS names troubleshooting with access to patient information as one of the things that makes a vendor a business associate.

You don't have to take our word for any of it. Here is how to check it yourself with a network monitor.

What this means, and what it doesn't

It means

  • There is nothing to sign with Safeclip for the app as it ships. Recording, transcription and notes run on your computer, and Safeclip doesn’t receive them.
  • A breach of Safeclip’s servers would not expose your sessions. We hold your email, your license and payment records from Stripe, not your clients’ words.
  • Your notes don’t depend on us. If Safeclip went away, your recordings, transcripts and notes would still be files on your computer.

It doesn't mean

  • It doesn’t make Safeclip “HIPAA compliant”. HHS doesn’t certify products, and we don’t claim any certification.
  • You are still the covered entity. Your computer is now where the session lives, so its security is yours: the checklist below covers the basics, and the computer belongs in your risk analysis.
  • Cloud Ask with your own API key is different. If you turn it on, your question and the passages it includes go to the provider you chose. That is your arrangement with them, and you may need a BAA with that provider. Keep the pure-local lock on in Settings to rule it out.
  • The same goes for anything you connect through the local API, and for exports you save to a folder that syncs to a cloud service.
  • Feedback you send from the app reaches Safeclip. Leave client details out of it.
  • A group practice with a compliance team may still want a vendor review, or require a BAA from every vendor as policy. The IT one-pager below is for them.
  • State law and your licensing board can ask for more than HIPAA does, especially about consent to record.

“OCR does not endorse, certify, or recommend specific technology or products.”

HHS, Guidance on HIPAA & Cloud Computing (last reviewed December 23, 2022; archived copy)

Not every therapist is a covered entity in the first place. HHS lists psychologists and other providers as covered:

“...but only if they transmit any information in an electronic form in connection with a transaction for which HHS has adopted a standard.”

HHS, Covered Entities and Business Associates (last reviewed August 21, 2024; archived copy)

A cash-pay practice that never bills electronically may fall outside HIPAA. State privacy law and your ethics code still apply, and the checklist below is good practice either way.

Your device checklist

Your notes are as safe as the computer they live on. Six things, for macOS, Windows and Linux. Most take a few minutes once.

  1. 01Turn on full-disk encryption

    If the computer is lost or stolen, encrypted data can’t be read without your password.

    Mac
    System Settings, Privacy & Security, FileVault. Turn it on and store the recovery key somewhere safe.
    Windows
    Windows 11 Pro: search for “Manage BitLocker” and turn it on for the system drive. Windows 11 Home: Settings, Privacy & security, Device encryption, on PCs that support it.
    Linux
    Encryption (LUKS) is chosen when you install. Run lsblk -f: an encrypted disk shows crypto_LUKS. Adding it later usually means reinstalling, so back up first.
  2. 02Use your own login, with a password and a screen lock

    Encryption protects a computer that is off or locked. A password only you know, and a lock when you step away, keep it that way.

    Mac
    System Settings, Lock Screen: require a password immediately after the screen saver or sleep. Lock now with Control-Command-Q.
    Windows
    Settings, Accounts, Sign-in options: require sign-in when you've been away. Lock now with Windows+L.
    Linux
    GNOME: Settings, Privacy (Privacy & Security in newer versions), Screen Lock, with automatic lock on. Lock now with Super+L.
  3. 03Back up, encrypted

    A backup is another copy of every session. Keep it as safe as the computer.

    Mac
    Time Machine to an external drive, with “Encrypt backups” on.
    Windows
    Back up to an external drive encrypted with BitLocker To Go.
    Linux
    Backups (Déjà Dup) with an encryption password, or an encrypted restic or Borg repository.
  4. 04Keep the system up to date

    Most attacks use holes that already have a fix. Safeclip updates itself; the operating system is up to you.

    Mac
    System Settings, General, Software Update, with automatic updates on.
    Windows
    Settings, Windows Update. Let it install security updates automatically.
    Linux
    Turn on automatic security updates (unattended-upgrades on Ubuntu and Debian, dnf-automatic on Fedora).
  5. 05Know who else uses the computer

    A shared family laptop with one login shares your sessions too.

    Mac
    Give anyone else their own user account. Safeclip keeps its data inside your account's folder.
    Windows
    The same: one Windows account per person, and nobody else knows your password.
    Linux
    The same: one user per person. Safeclip's data sits in your home folder.
  6. 06Delete audio you no longer need

    Audio you no longer keep can’t be lost or stolen. Transcripts and notes stay when the audio goes.

    All
    In Safeclip, delete a recording after you finish the note, or set Settings, Keep recordings to 30 days, 90 days or 1 year.

One more, if HIPAA applies to you: add this computer and Safeclip to your risk analysis, and write down when you delete audio. Then tell your clients what you do. The consent kit has the words →

For IT and practice admins

Everything a locked-down work computer needs on one page: what Safeclip installs, where its data lives, the hosts to allow and how the installers are signed.

Download the IT one-pager (PDF)

One page, US Letter. Updated October 19, 2026.

Hosts to allow

  • api.safeclip.ioUpdate checks, feedback; sign-in and license check only if you sign in
  • huggingface.co, *.huggingface.co, *.hf.coModel downloads
  • github.com, api.github.com, release-assets.githubusercontent.com, objects.githubusercontent.comUpdates, the local AI server, speaker-detection models, link-import tool, the natural voice if you add it
  • ffmpeg.martin-riedl.de, johnvansickle.comOnly if the bundled ffmpeg is missing

And only when they apply:

  • Microsoft. Windows installer only, for the WebView2 runtime if the PC doesn’t have it.
  • The site you paste a link from. Only for items you imported from a link.
  • Your cloud AI provider. Only when you choose Send to Cloud.

Nothing listens on the network. Safeclip's local transcription and AI servers, and on Linux the server that plays recordings in its window, bind to 127.0.0.1.

Where data lives

  • macOS~/Library/Application Support/io.safeclip.desktop
  • Windows%APPDATA%\io.safeclip.desktop
  • Linux~/.local/share/io.safeclip.desktop

Installers and signing

  • macOS (.dmg). Signed with Safeclip’s Apple Developer ID and notarized by Apple.
  • Windows (-setup.exe or .msi). Not code-signed yet, so SmartScreen may warn on first run. Compare the file’s SHA-256 with the one on the release page, or allow it by hash.
  • Linux (.deb, .rpm or .AppImage). Packages are not signed. Compare the SHA-256 with the one on the release page.

Installers are on the download page. Questions from IT: z@safeclip.io.

Next: what you tell your clients

No BAA doesn't mean no consent. Illinois, Maine and Colorado now require written consent before AI records or transcribes a therapy session. The consent kit has a script, a form paragraph and a client handout.

Consent kit·What leaves your computer·Security·Safeclip for therapists