Guide

Health data under the DPDP Act, practically.

What India’s data protection law asks of a hospital, which obligations land on your software and which land on your processes, and the questions worth putting to any vendor.

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10 minute read · Updated 07/09/2026

The Digital Personal Data Protection Act 2023 governs how personal data is collected, used and retained in India. For a hospital, health data is the most sensitive category it holds, and most of the obligations are process obligations that software can support but cannot discharge.

The obligations, in the order they affect you

Five, and only two of them are really software questions.

Notice and consent
People must be told what you are collecting and why, in language they understand, and consent must be as easy to withdraw as it was to give.
Purpose limitation
Data collected for treatment is not automatically available for marketing, research or anything else. Bundled consent covering everything is precisely what the Act is aimed at.
Retention
Data is kept for as long as the purpose requires or the law demands, and not indefinitely because deleting is inconvenient.
Rights
People can ask what you hold, ask for corrections, and in defined circumstances ask for erasure, subject to statutory retention that a hospital genuinely has.
Security
Reasonable safeguards, and breach notification. "Reasonable" is doing more work in that sentence than most vendors admit.

What lands on your software

Access control that is real rather than cosmetic, meaning a permission a role does not hold is refused on the server, not merely hidden in a menu. An audit trail that can answer who read what. Encryption in transit and at rest. Isolation, if the software is multi-tenant, that a hospital can verify rather than take on trust.

Then the harder ones, which most systems do not have: a workflow for handling a correction or erasure request, retention rules that actually delete something, and consent recorded per purpose rather than as a single tick at registration.

What lands on you

Your notice, your consent process at the desk, your retention policy, your breach response, your staff training, and your contracts with everyone who processes data on your behalf, which includes your software vendor.

Software cannot make a hospital compliant. It can make compliance evidenceable, which is a different and more modest claim.

Questions worth putting to a vendor

These separate a considered answer from a confident one.

Where is the data, physically?
Not "the cloud". Which country, which region, and is that configuration or architecture?
Who else touches it?
A named sub-processor list, what each handles, and whether you are told before it changes.
How is one hospital separated from another?
In a multi-tenant system, ask whether isolation is enforced by the database or by application code, and how it is tested.
What does the audit trail actually record?
Writes are easy. Reads are the interesting question under a privacy law.
What happens when we leave?
Export format, timescale, cost, and what happens to the copy they keep.

Where we stand

Nirogix has database-enforced tenant isolation, role-based access with per-user overrides that can be time-bound, an append-only audit trail, encryption in transit and at rest, India-resident storage, and a named sub-processor list published on our security page.

What we do not have yet is a patient-facing rights workflow: no self-service access request, no correction request and no erasure workflow with statutory holds. There is no purpose-scoped consent registry either. Both are scheduled. A hospital under scrutiny today would handle those requests as a process, with our support, rather than through a screen.

Questions this raises

Does the DPDP Act apply to a small clinic?

Yes. The obligations scale with the volume and sensitivity of the data, and health data is sensitive at any volume. A small clinic has fewer records, not fewer duties.

Can a patient ask us to delete their record?

They can ask. Erasure is subject to statutory retention obligations, which for clinical records are real. The right answer is usually a documented decision rather than a straight yes or no.

Is consent at registration enough?

For treatment, generally. For anything else, whether marketing, research or sharing beyond the care team, the Act is aimed squarely at the bundled consent that tries to cover everything at once.

Do you have a data processing agreement?

One is being prepared as part of our legal documentation. Until counsel has reviewed it, we are not publishing a draft and calling it binding.

See it running with your own workflows.

Book a walkthrough and we will map your clinic or hospital onto the platform, module by module.