Breach Response & Ransomware Readiness (DPDP for Healthcare)

What you must do when a personal data breach happens


A) Inform affected patients (Data Principals) — without delay

On becoming aware of a breach, the Data Fiduciary must intimate each affected Data Principal in a concise, clear and plain manner and without delay, through their user account or any registered communication mode. The intimation must include specific elements (what happened, consequences, mitigation, safety steps, and contact).

B) Inform the Board — immediate + detailed within 72 hours

On becoming aware of a breach, you must inform the Board without delay with a description and likely impact, and then provide updated and detailed information within 72 hours (or a longer period if allowed by the Board upon written request).

Who this page is for

  • Hospitals & multi-speciality chains (HIS/EHR, IPD/OPD, billing, discharge)
  • Labs + imaging centres (LIS/PACS + report delivery)
  • Telemedicine platforms (video consults, chat, prescriptions)
  • Healthcare SaaS vendors processing patient data (CRM, call centers, WhatsApp/SMS, analytics)

30-minute “first response” checklist

Trigger: Any suspicious access/exfiltration, ransom, leaked credentials, exposed bucket, compromised vendor.

1) Contain (stop the blast radius)

  • Isolate infected endpoints/servers (HIS/EHR/PACS/LIS segments)
  • Disable compromised accounts / API keys
  • Block suspicious outbound traffic
  • Freeze non-essential integrations temporarily (CRM, WhatsApp vendor, analytics)

2. Preserve evidence (don’t destroy your timeline)

  • Capture system logs, access logs, firewall logs
  • Preserve ransomware note / IOC indicators
  • Snapshot affected servers (if safe)
  • Preserve vendor communications + incident tickets

3. Classify impact (patient harm first)

  • Which systems impacted? (OPD, IPD, lab reports, radiology, billing)
  • Which patient groups impacted? (children, chronic care, sensitive departments)
  • What types of data likely affected? (identifiers, clinical notes, reports, contact info)
  • What is the operational impact? (downtime, delayed care, diversion)

4. Start the DPDP breach record

  • Awareness time (T0)
  • Awareness time (T0), decision log, incident commander
  • What you know vs what you suspect
  • Actions taken + next steps

What your patient notification must contain

our message to each affected patient must include all five items below:

  1. What happened (nature, extent, timing)
  2. Likely consequences relevant to them
  3. Mitigation measures you implemented / are implementing
  4. Safety measures the patient can take
  5. Business contact info of a person who can respond to queries

Micro-template (short, plain-English)

Subject: Important update about your data security
What happened: [brief description + timing window]
What data may be affected: [high-level categories only]
What this could mean for you: [likely consequences]
What we’re doing: [containment + recovery steps]
What you can do: [password reset, vigilance, contact channels]
Contact: [name/role + phone/email]

Your Board report sequence should cover

  1. Immediate description without delay (nature, extent, timing, location, likely impact)
  2. Detailed update (within 72 hours): Provide updated and detailed information including:
    • Broad facts: events, circumstances, reasons leading to breach
    • Mitigation measures implemented/proposed
    • Findings (if any) about person who caused the breach
    • Remedial measures to prevent recurrence
    • Report of intimations given to affected Data Principals

Ransomware readiness (resilience-by-design)

Healthcare ransomware is not just “data exposure”—it’s availability compromise, which DPDP Rules explicitly anticipate via continued processing measures like backups.

Minimum safeguards checklist (what to implement)
DPDP Rules list minimum “reasonable security safeguards” that should exist to prevent breaches, including:

  • Encryption/obfuscation/masking/tokenisation where appropriate
  • Access controls for your systems and your processors’ systems
  • Visibility via logs, monitoring, review for detecting unauthorised access and investigation
  • Backups / continuity measures for continued processing when CIA is compromised
  • Log retention (keep logs/personal data for 1 year unless law requires longer)
  • Processor contracts must include safeguard obligations

“Hospital-grade” ransomware controls (practical)
DPDP Rules list minimum “reasonable security safeguards” that should exist to prevent breaches, including:

  • Separate network zones: HIS/EHR, PACS, LIS, billing, admin
  • Immutable backups + routine restore drills (not just backup “existence”)
  • MFA for admin + remote access; disable shared logins
  • Patch cadence for radiology workstations and legacy endpoints
  • Vendor remote access with approvals + session logs

One-page operational SOP

  • Incident response team + on-call matrix
  • Backup + restore test schedule
  • Vendor escalation contacts and SLAs
  • Centralised logging and monitoring
  • Contain systems + disable compromised credentials
  • Preserve evidence snapshots
  • Decide service continuity path (downtime procedures)
  • Impact classification (systems + patients + data types)
  • Draft patient notification (plain-English)
  • Prepare Board “without delay” intimation
  • Submit detailed Board update: causes, mitigation, findings, preventive actions, patient intimation report
  • Root cause analysis + hardening plan
  • Retention/cleanup of exposed artifacts
  • Post-incident tabletop drill + lessons learned

Vendor / Processor checklist

Because many healthcare systems rely on processors (cloud, HIS vendor, WhatsApp/SMS vendor, call center, lab systems), ensure:

  • Contracts require reasonable security safeguards
  • Access controls + least privilege for vendor accounts
  • Logs + monitoring + review for detection and remediation
  • Backup/continuity expectations for critical vendors
  • Incident cooperation clause: evidence preservation, timelines, patient-facing comms support
  • Sub-processor visibility and escalation contacts

Quick compliance checklist

  • Patient notice content includes all 5 required items
  • Board is informed without delay + detailed update within 72 hours
  • Logs/monitoring exist for detection and investigation
  • Backups + continuity measures exist and are tested
  • Vendor contracts include safeguard obligations

Is your Incident Response Team ready?

We can set up your breach kit: patient notification templates, Board reporting pack, ransomware SOP, and vendor incident clauses—tailored to HIS/EHR + lab + telemedicine workflows.