Data Security in Hospitals & Diagnostic Centres: What the New DPDP Rules Mean for Healthcare

With the Digital Personal Data Protection (DPDP) Rules notified on 14 November 2025, India has formally entered a new era of healthcare data governance. For hospitals, diagnostic centres, radiology chains, pathology labs, and telemedicine players, this isn’t just a compliance requirement, it is a core patient-trust issue.

Healthcare providers handle the most sensitive category of personal data. A single breach in healthcare data security system can impact clinical care, patient confidence, and institutional credibility.

This article breaks down what the DPDP Rules mean specifically for healthcare and how providers should respond.

1. Hospitals & Diagnostic Centres Are Now Data Fiduciaries

Under the DPDP framework, healthcare institutions are treated as Data Fiduciaries, responsible for:

• How patient information is collected

• How it is stored & processed

• Who gets access & why

• Safeguarding it against breaches

Large networks and high-volume diagnostic chains may additionally qualify as Significant Data Fiduciaries, triggering deeper compliance obligations.

2. Consent Is Now Purpose-Specific

General consent is no longer enough.

Healthcare institutions must now ensure:

• Purpose-bound consent (admission, diagnostics, billing, reporting all need clear intent)

• Traceability (who gave consent, when, for what)

• Easy withdrawal (patients can revoke consent anytime)

Expect major changes in OPD/IPD forms, lab registration flows, and digital consent processes.

3. Stronger Security Standards

DPDP demands “reasonable security safeguards,” which in healthcare translates to:

• Encryption of medical records, lab results, images

• Strict role-based access (doctor vs nurse vs billing vs radiology)

• Regular audits of HIS/LIS/PACS

• Incident & breach response workflows

• Monitoring for unauthorized access

Ransomware attacks on hospitals have increased globally — DPDP makes defence mandatory, not optional.

4. Data Retention & Erasure Requirements

While medical records must be preserved for medico-legal periods, DPDP emphasises:

• No indefinite storage

• Timely deletion or anonymisation

• Proper retention logs

• Secure disposal protocols

Hospitals must align DPDP rules with MCI/NABH/NABL norms to avoid conflict.

5. Children’s Data: Conditional Exemption

DPDP Rules provide limited relief:

Healthcare providers may process children’s data without parental consent only when:

• It is essential for treatment

• It directly relates to the child’s health

But this cannot be used for marketing, profiling, or any secondary purpose.

6. Operational Compliance Now Mandatory

Healthcare providers must prepare for significant operational shifts:

• Appoint a Data Protection Officer (DPO)

• Conduct Data Protection Impact Assessments (DPIA) for high-risk digital operations

• Publish patient-facing grievance contacts

• Update contracts with third-party processors (cloud, LIS/HIS vendors, call centers)

• Train all clinical & operations staff

DPDP compliance will likely become a NABH evaluation point in future cycles.

7. Cross-Border Data Transfers Are Regulated

Labs or hospitals using:

• International cloud servers

• Overseas radiology teleradiology partners

• Global research collaborators

…must ensure transfers meet DPDP conditions. Compliance clauses in contracts are now essential.

What Healthcare Leaders Should Do Now for Healthcare Data Security:

Early Actions

• Map all patient data flows (HIS, LIS, PACS, CRM, website)

• Review consent forms & workflows

• Begin gap assessment for DPDP compliance

Short-Term

• Upgrade cybersecurity posture

• Train staff on data handling protocols

• Update vendor agreements

Long-Term

• Implement consent-management systems

• Establish a privacy governance framework

• Conduct periodic audits

Data governance must become a board-level agenda for all healthcare businesses.

The DPDP Rules are not just a legal obligation, they represent a cultural shift toward transparency, patient control, and digital ethics. Hospitals and diagnostic centres that act early will not only reduce risk but also earn stronger patient trust.

Disclaimer:

This article & suggestive interpretation of DPDP Act is for general informational purposes only and does not constitute legal, regulatory, or professional advice. Readers are advised to verify all information independently and consult qualified legal or compliance professionals before making any decisions or implementing any policies related to data protection or otherwise.

Healthcare organisations must review their specific operational, legal, and regulatory requirements before taking any action& may refer to  Ministry of Electronics and Information Technology Notifications.