Does @notionhq/notion-mcp-server send data, and where? — data-flow verdict

100/100 integrity 100% evidence coverage evidence-backed Measures evidence support, not confidence — how this is scored

Verdict (the facts)

Tool: npm/@notionhq/notion-mcp-server
Integrity axis: undisclosed_processing — Observed behaviour matches the tool's stated function; the egress above is the tool doing its advertised job. 'honest' is the integrity axis — it does NOT imply the data flow is irrelevant; see the data-flow axis and jurisdiction.
Data-flow axis: Sends data to api.notion.com (US, jurisdiction tier 2) as its core function. No telemetry, analytics or error-reporting side-channel was found (full source + dependency-tree review). Where your data goes is determined by the tool's stated purpose, not by a hidden observability channel.
Disclosure: functional — Single egress destination: api.notion.com (Notion Labs, Inc., US) — the Notion REST API the server exists to call, authenticated with the user's integration token (NOTION_TOKEN). Zero telemetry/analytics/error-reporting: confirmed by a grep of the package and its full transitive dependency tree for all common observability SDKs. The workspace data it carries (search queries, page/database IDs and content) is the tool's advertised function, not a side-channel.
Capture self-test: verified
Severity: low — integrity axis only (undeclared exfiltration). Functional egress and disclosed metadata are reported as neutral facts and are not graded here.
Version (pinned): 2.2.1 · commit d802a0cd7d77c77b0a659be3fd98a9a23975b6e9
Content hash: sha256:3d1b0d2355ca2555db2721a198f15bd819489048771f1fc54ac0f0df012f4b0e
Signature: ed25519:PsZ6M6XFGivRdgeHYbVYVCZM9mQIbbMRTEru6W… · Ed25519 public key · sha256:49cf8457b42a7048
Scanned: 2026-06-14T00:00:00Z — Pinned to @notionhq/notion-mcp-server@2.2.1 (git d802a0cd7d77c77b0a659be3fd98a9a23975b6e9), published 2026-03-05. This verdict applies to that exact version; a newer release would require a re-scan.
Re-verified: 2026-06-14 — pinned version current
Categories: project-productivity functional-egress US published
Observation history: 1 scan(s); first seen 2026-06-14T00:00:00Z · latest 2026-06-14T00:00:00Z

Observed egress destinations

host	country	jurisdiction	class	disclosure	frequency	kind
api.notion.com	US	tier 2	functional	by purpose	on launch and on every tool call	Notion REST API — carries workspace search queries, page/database IDs and content (the tool's advertised function)

Each destination is classified FUNCTIONAL (the tool's advertised job requires the call — a neutral fact about where your data goes), SESSION/AUTH (handshake with the same operator), or TELEMETRY/ERROR_REPORTING (an observability side-channel not required for the function). Disclosure is judged across the tool's full public doc surface, not just its README, and any 'undisclosed telemetry' finding is adversarially refuted before it is asserted.

Jurisdiction context: Tier 2 = third country (e.g. US): transferring EU personal data to a third country requires a transfer basis under GDPR Art. 44-49 (e.g. SCCs / EU-US Data Privacy Framework) — an obligation on you, the deployer; the tool gives no control over this flow. This is the applicable framework, not a finding that the tool violates it.

Evidence — the captured request (verify, don't just trust)

Capture self-test: verified — a beacon decoy was emitted from the tool's network context; its presence in the intercept means a 'no egress' result would have been trustworthy.

Observed: GET https://api.notion.com/v1/users/FILE-CONTENT%3A%3Acanary-21dc3a86-file-865c04a1d7dd%3A%3AEND ×22 — intercepted (the tool's HTTPS was terminated against the sandbox CA; the egress was then blocked by strict-egress, but the full request was captured)

Payload fields actually sent:

Notion-Version
query
start_cursor
children
after
parent
icon
cover
rich_text
sorts
title
description

Captured payload sample (one event):

{"Notion-Version":"FILE-CONTENT::canary-21dc3a86-file-865c04a1d7dd::END","parent":"FILE-CONTENT::canary-21dc3a86-file-865c04a1d7dd::END","properties":{},"children":["FILE-CONTENT::canary-21dc3a86-file-865c04a1d7dd::END"],"icon":"FILE-CONTENT::canary-21dc3a86-file-865c04a1d7dd::END","cover":"FILE-CONTENT::canary-21dc3a86-file-865c04a1d7dd::END"}

Captured in the sandbox run. The distinct_id (a persistent machine identifier) and the write-only, public-by-design ingestion key are truncated above; payload_fields is the union observed across the run.

Reproduce it yourself (canary-sandbox (open methodology; Docker backend)):
python -m canary.cli scan <target> --backend docker # target: npm @notionhq/notion-mcp-server@2.2.1
Re-run it yourself: the scanner installs the pinned version, drives the tool over MCP, and intercepts all egress.

Full raw captured trace + verification: /verdict/notion/evidence.json — every captured request (redacted), the verdict content-hash and the package checksum, for an AI or auditor that wants the underlying observation, not just the conclusion.

Disclosure check (the §824 evidence)

Read: package source + full transitive dependency grep (zero observability SDKs); official @notionhq/notion-mcp-server docs
Quoted from the tool's own docs: “”
Match: Single egress destination: api.notion.com (Notion Labs, Inc., US) — the Notion REST API the server exists to call, authenticated with the user's integration token (NOTION_TOKEN). Zero telemetry/analytics/error-reporting: confirmed by a grep of the package and its full transitive dependency tree for all common observability SDKs. The workspace data it carries (search queries, page/database IDs and content) is the tool's advertised function, not a side-channel.
Residual gap: Workspace PII lands in Notion's US cloud — relevant to any EU/GDPR transfer obligation, which is the deployer's responsibility. Absence of a privacy doc is not a gap here: there is no telemetry flow to disclose.

How we know this — claims by basis

Observed — directly in the capture, reproducible

The tool sent 22 request(s) to api.notion.com carrying fields: Notion-Version, query, start_cursor, children, after, parent, icon, cover, rich_text, sorts, title, description. — Captured in the sandbox run (published redacted in the evidence artifact); re-run the scan to reproduce. (confidence: high)

Inferred — our reasoning over the observation

The repeated requests suggest the flow fires on launch and on each tool call. — 22 requests in one run — an inferred pattern, not proven across launches. (confidence: medium)

Classified — our adversarially-reviewed judgment

api.notion.com is classified as functional (required for the tool's advertised function). — Adversarially reviewed. (confidence: high)
Disclosure status: functional. — Single egress destination: api.notion.com (Notion Labs, Inc., US) — the Notion REST API the server exists to call, authenticated with the user's integration token (NOTION_TOKEN). Zero telemetry/analytics/error-reporting: (confidence: high)

Method

Installed and run in an isolated container; fed traceable decoy data; all outbound traffic intercepted (TLS broken via own CA, iptables transparent redirect). Endpoints, resolved geo/jurisdiction and frequency are observed facts. Capture self-test passed.

Scope

Compares the tool's declared destinations against what was observed in one sandbox run. Checks transparency / integrity for a cooperative tool, NOT resistance to deliberate evasion. "honest"/"clean" means "observed without deviation within our reach", NOT "guaranteed no hidden egress". Out of scope: exfiltration split/chunked across requests; tool-side encryption of the payload before egress; input/time/state-triggered processing not triggered in the run.

Machine-readable verdict: /verdict/notion.json. This page describes observed behaviour and its relation to the tool's own disclosures — it is not a legal judgment. Search context: does @notionhq/notion-mcp-server send data, @notionhq/notion-mcp-server privacy, @notionhq/notion-mcp-server data flow, @notionhq/notion-mcp-server telemetry, where does @notionhq/notion-mcp-server send data, is @notionhq/notion-mcp-server safe, what data does @notionhq/notion-mcp-server collect, how to disable @notionhq/notion-mcp-server telemetry, @notionhq/notion-mcp-server opt out tracking, @notionhq/notion-mcp-server GDPR data residency, @notionhq/notion-mcp-server third-party / jurisdiction.