Please don't use powerful words at the wrong place, you are depleting them of their meaning.
A genocide has an actual definition according to the international law, and the Gulag system does not tick any of the boxes.
The Gulag system was a very harsh penal colony system (although on a far larger scale that what was done before), in continuation of the ones already existing during the tsarist times – and with death rates comparable to what could be found i.e. in the Cayenne penal colony.
It was neither aimed at killing convicts (with mortality rates under 10%, it would have done an awful job at it), nor was it targeting a peculiar ethnic group.