9/25/2025 · 8–10 min dpdp privacy compliance security india
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TL;DR — Treat patient data with purpose limitation, consent, and safeguards. Be transparent, minimize collection, control access, and keep audit trails. Work with vendors who support exports, deletion, and incident response.
Your clinic is typically a “data fiduciary.” Vendors (EMR, billing, SMS) are “data processors.”
Obtain, record, and honor consent where required; respect withdrawal and access/correction requests.
Collect only what you need for care, billing, and operations. Avoid “nice-to-have” fields that increase risk.
Notices: clear purpose, retention hint, contact route for requests.
Consent: when needed, keep a record of how/when captured.
Purpose limitation: use data only for stated purposes.
Data minimization: avoid collecting extraneous personal data.
Security: role-based access, encryption in transit/at rest where possible, audit logs, backups.
Retention and deletion: keep data only as long as necessary and lawful; define destruction workflows.
Accountability: assign an owner (privacy lead) and maintain a light data inventory.
Tip: A simple, one‑page privacy notice at registration plus an internal SOP often covers 80% of operational needs.
Create a simple intake channel (email/web form/WhatsApp business) and SOP for:
Access and copies of records (timelines and fees per local norms)
Correction/updates (demographics, contact details)
Consent withdrawal (e.g., marketing messages)
Deletion requests where legally permissible (consider medical record retention rules)
Data location disclosed and acceptable to your policy
Backups and disaster recovery posture
Export formats (PDF, CSV, FHIR, JSON) and no lock‑in
Deletion on request with documented SLA
Sub‑processor transparency
Breach notification commitments
Unique logins for every staff member; no shared passwords
Least‑privilege access; reception doesn’t need clinical notes
Screen privacy in reception areas and wards
Logged session timeouts for unattended devices
Phishing awareness and safe file‑handling practices
ABDM encourages structured, interoperable health data exchange. Good DPDP hygiene (consent capture, purpose limitation, data minimization) makes future interoperability safer and simpler.
Assign a clear owner. For small clinics, an operations lead with training usually suffices.
Follow clinical/legal retention policies for your specialty and jurisdiction. Document your policy and apply it consistently.
Many clinics do, but use business accounts, avoid sharing unnecessary details, and document the consult in the EMR.
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