DPDP for Healthcare & Hospitals: The Compliance Playbook
Patients, caregivers, and clinicians—healthcare handles India’s most high-impact personal data. Here is your roadmap to safety and compliance under the DPDP Act.
Why Healthcare Compliance is High-Risk
High Impact, High Trust. Healthcare organisations process deeply personal information—patient identifiers, clinical records, diagnostics, prescriptions, billing, and communications. Under the DPDP Act, your compliance posture must be designed around clear notices, controlled sharing, strong safeguards, and incident readiness.
- High breach impact: ransomware, downtime, and exposure of patient records
- Complex access: many roles and departments touch data daily
- Vendor-heavy stack: HIS/LIS/PACS, labs, TPAs/insurers, cloud tools
- High-volume communications: reminders, follow-ups, WhatsApp/SMS outreach
Who You Need to Protect
- Patients (OP/IP, chronic care, diagnostics, telemedicine users)
- Caregivers & Guardians (especially for children and dependent patients)
- Doctors, Nurses & Staff (workforce personal data + access accountability)
Critical Risk Signals in Healthcare
Most healthcare DPDP risks come from day-to-day operations—not from “policy gaps.” If any of these apply, you should prioritise controls early.
- Shared logins or weak role-based access across departments
- Patient data sent over WhatsApp/SMS without clear purpose and controls
- Third-party labs, imaging, TPAs, or CRM tools processing patient data without tight contracts
- Long retention of reports, recordings, or exports without deletion workflows
- No incident playbook for ransomware or unauthorized access
The Healthcare Data Journey
Registration & Onboarding
Patient demographics, IDs, contact details, ABHA/health IDs (if used), consent capture.
Clinical Care & EMR/EHR
Doctor notes, prescriptions, vitals, procedure details, discharge summaries, care plans.
Diagnostics (Lab + Imaging)
Lab reports, radiology, imaging storage (PACS), diagnostic sharing with clinicians.
Billing, Claims & TPA/Insurance
Invoices, payment records, claims coordination, authorisations, reimbursement workflows.
Follow-ups & Patient Engagement
Reminders, telemedicine sessions, post-care follow-ups, feedback surveys, health camps.
User Rights Portal (Patients & Caregivers)
A self-serve portal blueprint for access, correction, deletion requests (where applicable), and grievance redressal.
Retention Schedules for Medical Records
Define retention, archiving, legal holds, and deletion workflows across EMR/EHR, diagnostics, billing, and support systems.
SaaS & Vendor Map (HIS/LIS/PACS/TPA)
Inventory every processor and sub-processor touching patient data—cloud, labs, imaging, CRMs—and control cross-border exposure.
Implement DPDP in 30 / 60 / 90 Days
30 Days: Quick Wins
- Map data journey + systems + vendors
- Fix notices on registration/telemedicine/marketing
- Set up a basic rights & grievance workflow
60 Days: Core Controls
- Role-based access + audit logs
- Vendor contracts + processing inventory
- Retention schedule + deletion SOPs
90 Days: Operational Readiness
- Incident response + ransomware drill
- Automated request tracking + reporting
- Ongoing compliance monitoring and internal review
Are you a Significant Data Fiduciary (SDF)?
Large hospital groups, national healthcare platforms, and high-volume processors may be designated as SDFs. This can trigger additional obligations such as periodic audits, impact assessments, and stronger governance—so it’s worth planning early.
Not sure where to start?
Run DPDP CheckMate to get a Healthcare-focused readiness score and a prioritized action plan based on your workflows.