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Request for Inputs: NDHM|Draft Health Data Management Policy

September 7, 2020

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Dear Members,

The National Health Authority (NHA) has released the Draft Health Data Management Policy (NHD Policy). This policy would act as a guidance document across the National Digital Health Ecosystem (NDHE) and sets 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.

The policy intends to digitise the entire healthcare ecosystem of India. This would be done by creating digital health records and creating and maintaining registries for healthcare professionals and health facilities in order to ensure a smooth interoperable framework for the multiple partners associated with healthcare delivery to individuals in India. In line with the  National Digital Health Blueprint, 2019, a federated architecture will be adopted  to ensure interoperability, technological flexibility and independence across the National Digital Health Ecosystem.

 Given that the Personal Data Protection Bill, 2019, (PDP bill) which is currently being considered by the Parliament, is a horizontal legislation that would cover privacy of health/ medical data also, the interplay between PDP bill and NHD policy requires careful consideration. The way the NHD policy, envisages identifiers for individuals, health care providers, etc, the intended use and the mode of functioning also merit careful consideration.

 We would like to have your feedback on the draft policy. The deadline for providing feedback to NHA is 21 September 2020.

Request to share your inputs to jayakumar@nasscom.in / komal@nasscom.in by 16 September 2020.


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Komal Gupta
Policy Analyst

Policy Professional| Former Tech and Business Journalist|

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