Notion (notion.so) - Vendor Security Precheck: Medium Review
Interpretation: "Notion, notion.so" is read as Notion Labs, Inc., the productivity workspace vendor. The site footer reads "© 2026 Notion Labs, Inc.". notion.so now serves the same pages as notion.com. All access dates are 5 October 2026.
Summary: Notion publishes a Wolfia-hosted trust center listing SOC 2 Type II, ISO 27001 and other certifications, with reports gated behind an access request. No origin registry confirmed any certification, so all are marked "claimed". There is a public DPA link, a subprocessor list (about 26 entries by my count), and AWS data residency for Enterprise. Three security items between December 2025 and July 2026 need follow-up questions; none is a confirmed customer-data breach. Tier: Medium.
Vendor table
| Vendor | SOC 2 | ISO 27001 | Other certs | Trust center | DPA available | Subprocessors listed | Data regions | SSO | Incidents (last 3 years) | Gaps to ask about | Tier |
|---|---|---|---|---|---|---|---|---|---|---|---|
| Notion | Claimed, Type II (annual audits); report via "Request access" | Claimed (also ISO 27017, 27018, 27701); certificate via "Request access" | HIPAA claimed (needs Enterprise features plus a signed BAA, per security page); BSI C5 claimed; SOC 3 listed on trust center. PCI DSS, FedRAMP, CSA STAR, HITRUST: none found. Trust center lists a CAIQ (CSA self-assessment) dated July 2026, which is not a STAR registry entry | trust.notion.com | Public link on trust center; contents not opened (see Coverage) | Yes (trust center tab; I counted 26 on the overview, counting rule not verified and the page may include affiliates; list date not found) | AWS. Enterprise-only residency: US-West-2 (Oregon), EU-Central-1 (Frankfurt), AP-Northeast-1 (Tokyo) and others; default US | SAML 2.0 on Business and Enterprise; SCIM and audit log for Enterprise per security page. Two-step verification on all plans (SMS, TOTP, passkeys, backup codes) and SCIM via Okta and Entra ID, per trust center (vendor-stated). OIDC: not found | 3 items (Dec 2025 to Jul 2026), none a confirmed customer-data breach (see notes) | Audit report scope and dates; DPA and SCC terms; open items below | Medium |
Notes on the Medium rating
- Certifications are vendor-stated only. The trust center lists SOC 2 Type II, ISO 27001/17/18/701, HIPAA and BSI C5, and offers the SOC 2 report and ISO certificate through "Request access". I did not check an auditor letter or certification-body registry, so nothing is "verified". The SOP's Low tier needs a verified certification, so this rating is Medium, not Low. The reports exist on request, so I did not rate it High.
- Residency limits. Residency is free for Enterprise, but workspaces stay in the United States until migrated. Account information, usage data and subprocessor-processed data can sit outside the chosen region. Notion Calendar, Notion Mail and beta services are excluded. Japan and Korea hosting needs the account team.
- June 2026 breach claim, denied by Notion. On 29 July 2026 Notion said a claim of a large dataset for sale on X and Breached Forums, first seen 23 June 2026, was fabricated. It found no evidence customer data was accessed. This is Notion's own account, with third-party support.
- April 2026 public-page email exposure. CyberInsider, 20 April 2026 reported that an unauthenticated API call on published pages can return contributor emails. A 2022 HackerOne report was reportedly marked informative. Notion's Max Schoening reportedly said the current behavior is insufficient and that fixes are being explored. I did not find a fix confirmation.
- January 2026 Notion AI exfiltration. PromptArmor reported data exfiltration through indirect prompt injection. The report was first closed as "Not Applicable" via HackerOne on 29 December 2025. PromptArmor says Notion had a fix in production by 7 January 2026. This points to bug-bounty triage gaps.
Do next
- Request the SOC 2 Type II report and ISO 27001 certificate through the trust center (NDA likely); check the auditor, period and exceptions.
- Ask whether public-page contributor emails are still exposed and when the fix ships; decide whether staff may use "Publish to web".
- Ask which Notion AI subprocessors (for example the AI model hosts listed on the trust center) apply to your plan, and confirm zero data retention. Notion says it applies to Enterprise workspaces.
- Confirm the plan tier you need: SAML needs Business or Enterprise, and residency needs Enterprise.
- Confirm OIDC support and enforcement of two-step verification, and review the DPA and SCCs.
Open items
- Subprocessor list date and change-notice terms not found; the Notion-hosted list returned an empty body.
- The security.txt file points to a disclosure policy (expires 2030-01-01). The trust center and security page state a HackerOne bug bounty; the HackerOne page itself returned empty, so program scope and payouts are unchecked.
- Search results also named CVE-2025-69207 (OAuth IDOR) and a September 2025 AI-agent data-theft write-up on Schneier's blog. I did not open them, so they are leads, not findings.
- I did not check status page history.
Coverage
Reached: the Notion security page, trust center, subprocessor tab, data residency and SAML help pages, security.txt, Notion's July 2026 security update, and two incident write-ups. Not reached or not checked: the HackerOne page (empty), the Notion-hosted subprocessor list, DPA and privacy policy text, FedRAMP, CSA STAR, PCI and HITRUST origin registries, Have I Been Pwned, state AG and HHS portals, the status page, SCIM and MFA help pages (vendor-stated on the trust center only). Tiers and gaps are recommendations to confirm, not a security assessment or legal advice.
Sources
- Notion security and privacy page (accessed 5 Oct 2026)
- Notion Trust Center (accessed 5 Oct 2026)
- Notion Trust Center, subprocessors (accessed 5 Oct 2026)
- Data residency for Notion, Help Center (accessed 5 Oct 2026)
- SAML SSO, Notion Help Center (accessed 5 Oct 2026)
- Notion security.txt (accessed 5 Oct 2026)
- Notion blog, Security update (July '26) (accessed 5 Oct 2026)
- CyberInsider, Notion public pages leak user data (accessed 5 Oct 2026)
- PromptArmor, Notion AI data exfiltration (accessed 5 Oct 2026)