Health Data Protection

Under the Digital Personal Data Protection Act, 2023 (DPDP Act), health data protection refers to protecting personal data related to an identifiable individual’s health information when it is collected, stored, processed, or shared by a Data Fiduciary or Data Processor. Health-related information may include medical records, diagnostic information, treatment details, insurance-related health information, and other data that identifies or relates to an individual.

Organizations such as healthcare providers, health technology platforms, insurers, and wellness applications may process health-related personal data across multiple systems. Protecting such data requires organizations to maintain visibility into where personal data exists, ensure processing occurs for defined purposes, implement appropriate security safeguards, and manage access to reduce risks of unauthorized disclosure or misuse.

The DPDP Act does not create a separate category called "health data" or prescribe health data-specific compliance requirements. However, health information may qualify as personal data when it relates to an identifiable individual. Organizations processing such information must comply with applicable DPDPA obligations, including providing notices, obtaining consent where required, implementing reasonable security safeguards, and protecting against Personal Data Breaches.

In practice, gaps emerge when:

• Organizations cannot identify all systems containing health-related personal data.
• Health information is shared without clear processing purposes or controls.
• Access to health-related personal data is broader than required.
• Third-party processing of health data lacks appropriate oversight.
• Organizations cannot determine affected health information during a data breach.

Organizations address these challenges by maintaining personal data inventories, mapping data flows, applying access controls, managing third-party processing, and maintaining privacy governance processes. Within Privy, capabilities such as data discovery, data classification, data mapping, consent management, and compliance reporting help organizations identify and manage personal data across complex environments.