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NHA: NASSCOM's Feedback on Health Data Management Policy 2.0
NHA: NASSCOM's Feedback on Health Data Management Policy 2.0

May 26, 2022

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The National Health Authority (NHA) had released the draft Health Data Management Policy 2.0 (HDMP 2.0) for stakeholder consultation.  The objective of this policy is to realise Ayushman Bharat Digital Mission’s (ADBM) guiding principle of “security and privacy by design” for the protection of individual’s/data principal’s personal digital health data privacy. It will act as a guidance document across the National Digital Health Ecosystem (NDHE) and set out the minimum standard for data privacy protection that should be followed across the board in order to ensure compliance with relevant and applicable laws, rules and regulations.                                                                                                               

We submitted our feedback on the draft Policy and noted that:

  • The definition of sensitive personal data must be narrowed down. It must be considered that the draft Policy is sector-specific and must restrict its applicability to the collection, processing, storage, sharing and retention of ABDM data. Such SPD may include health data conditions, electronic health records etc.
  • It may be considered that data fiduciaries can requires data processors to adhere to certain pre-qualified training programs or certifications to ensure security and safety of data. These may include SOC i.e., System and Organisation Control Reports, ISO Standards to safeguard personally identifiable information etc.
  • NHA should identify risks in dealing with NPD and require entities to ensure that those risks are addressed.

To read our detailed submission, kindly refer to the attached submission.


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Download Attachment

NASSCOM_HDMP V2.pdf

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Apurva Singh
Senior Policy Associate

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