DPDP for the Information security / SOC department in Healthcare

Reviewed by InfraVeritas360 ResearchFirst published 10 October 2026Last reviewed 11 October 2026

Sources: DPDP Act, 2023 and DPDP Rules, 2025 (MeitY) · Code of Medical Ethics, 2002 · MoHFW · Tamil Nadu health department FAQ · MTP Regulations

In a hospital, the SOC watches the HIS, PACS, LIS, the patient app and many connected devices. It usually sees an attack first.

Written for: Information security / SOC department, Healthcare and hospitals. Open this seat in the interactive tool

What is different here

Ransomware can stop admissions and lab work, so containment is planned with clinical leads. Snooping is the quieter risk: staff opening VIP, colleague or neighbour records. The SOC should watch for both.

The first four things to sort out

Alert on mass access or exports from the hospital information system and PACS.
Watch vendor remote sessions to imaging and lab devices.
Send weekly break-glass and flagged-record reports to the privacy lead.
Start the CERT-In six-hour clock and tell the DPO at once.

A worked example

Information security / SOC department

Many views of one well-known patient's record

10:00A public figure is admitted to the hospital.
14:00The SOC sees many users outside the care team opening the record.
Day 2The DPO and medical director get the log; the DPO assesses it and HR follows its process.
Week 1The record is flagged, and opening it now needs a reason.

Evidence kept

Alert
Access log extract
DPO assessment
Flag setting

Snooping is an incident too, and logs make it visible.

What others in the sector usually do. Some hospitals have the SOC flag unusual record views, such as many users opening the record of one well-known patient.

Where it usually goes wrong, by organisation type

Organisation type	Hotspots
Multi-specialty hospital chain	Shared logins on ward computers; Reports forwarded on messaging apps; VIP or staff records viewed out of curiosity
Standalone hospital or nursing home	Paper case sheets at nursing stations; Vendor remote access to the hospital software; Records room with no access log
Diagnostic labs and imaging	Report links sent to the wrong number; Franchisees keeping patient lists; PCPNDT records and images
Health-tech and telemedicine	Analytics and ad SDKs in health apps; Chat transcripts kept with no period; Sharing user data with partner pharmacies for offers
Pharmacy chain and e-pharmacy	Prescription images in the app and with stores; Refill reminders used for marketing; Delivery partners with addresses and order details

Control map: DPDP to NIST CSF 2.0 and ISO/IEC 27001:2022

DPDP duty	Law	NIST CSF 2.0	ISO/IEC 27001 Annex A	Evidence
Know where personal data is	Section 8(5) · Rule 6	ID.AM-02, ID.AM-07	5.9, 5.12	Inventory of systems and data types, with owner and hosting location
Only the right people get in	Section 8(5) · Rule 6	PR.AA-01, PR.AA-05	5.15, 5.16, 5.18, 8.2	Role matrix, quarterly access review sign-off, leaver removal report
Strong sign-in for admins and remote users	Section 8(5) · Rule 6	PR.AA-03	5.17, 8.5	MFA enforcement report for admin, VPN and email accounts
Encrypt or mask data	Section 8(5) · Rule 6	PR.DS-01, PR.DS-02	8.11, 8.24	Encryption settings for databases, laptops, backups and transfers; masking in test copies
Keep and watch logs	Section 8(5) · Rule 6	PR.PS-04, DE.CM-01, DE.CM-03	8.15, 8.16, 8.17	Log retention settings (one year; 180 days in India for CERT-In), alert rules, NTP source
Backups that restore	Section 8(5) · Rule 6	PR.DS-11, RC.RP-03	8.13, 5.30	Backup schedule, offline copy, last restore test with date and result
Separate networks	Section 8(5) · Rule 6	PR.IR-01	8.20, 8.22	Network diagram showing segments, firewall rule review
Patch and fix weaknesses	Section 8(5) · Rule 6	ID.RA-01	8.8	Vulnerability scan results and closure tracker
Handle incidents and tell people	Section 8(6) · Rule 7	RS.MA-01, RS.CO-02, RS.CO-03	5.24, 5.25, 5.26, 6.8	Incident plan with the 6-hour and 72-hour steps, drill record, contact list
Learn from incidents	Section 8(6) · Rule 7	DE.AE-02, ID.IM-01	5.27, 5.28	Post-incident review and actions closed
Vendors protect data too	Section 8(1)–(2)	GV.SC-05, GV.SC-07	5.19, 5.20, 5.22	Contracts with data terms, vendor review record
Data comes back or is deleted at contract end	Section 8(7) · Rule 8	GV.SC-10	5.20, 8.10	Exit clause and deletion certificate from the vendor
Cloud is set up safely	Section 16 · Rule 15	GV.SC-05, PR.DS-01	5.23	Cloud region list, shared-responsibility note, configuration review
Delete when the purpose is over	Section 8(7) · Rule 8	PR.DS-01	8.10, 7.14	Retention schedule, deletion log, disposal certificates for disks and paper
People know the rules	Section 8(5) · Rule 6	PR.AT-01	6.3	Training attendance and short test results by department
Legal duties are tracked	Section 8(5) · Rule 6	GV.OC-03	5.31, 5.34	Register of laws and rules that apply, reviewed yearly
Roles are named	Section 8(9)–(10) · Rules 9, 14	GV.RR-02	5.2, 5.4	Named owners for each system and each duty, approved by management

Logs, backups and access checklist

Logs. Access and activity logs for systems holding personal data are kept for at least one year (DPDP Rule 6 and Rule 8(3)).
Logs. ICT system logs are kept for 180 days, within India, as the CERT-In Directions of 28 April 2022 require.
Logs. System clocks are synced to the NTP servers of NIC or NPL, or to servers traceable to them, as CERT-In asks.
Clocks. Reportable cyber incidents can be reported to CERT-In within six hours of being noticed.
Clocks. Affected people and the Data Protection Board are told without delay, and the Board gets a detailed report within 72 hours.
Backups. At least one backup copy is offline or immutable, and a full restore was tested in the last six months.
Backups. Backup retention matches the retention schedule, so deleted records do not live on for years in old copies.
Access. Privileged and remote accounts use multi-factor sign-in.
Access. Access rights are reviewed every quarter, and leavers are removed on their last working day.
Access. Shared or generic logins are replaced with named accounts, or are tied to a named person in a register.
Vendors. Vendor remote access is named, time-bound and logged.
Test data. Test and training systems use masked data, not live copies.
Devices. Imaging and lab devices are on a separate network, with vendor access through a controlled gateway.
Downtime. Written downtime procedures exist for wards, labs and pharmacy, and were rehearsed this year.

10 questions the Information security / SOC department asks, answered in full

Imaging machines and lab analysers hold patient data. What do we do?

Short answer: Separate network, controlled vendor access, wipe before disposal

Imaging and lab devices store names, ages and results, often on old operating systems. Put them on a separate network, control vendor remote access, change default passwords, and wipe disks before a device is returned or scrapped.

What the law says

Rule 6 safeguards apply to devices that store personal data. Section 8(5) · Rule 6 · Section 8(7) · Rule 8

Steps

List devices that store patient data.
Segment them.
Control vendor remote access.
Change default passwords.
Wipe before disposal.

Evidence to keep

Device list
Network diagram
Wipe certificates

Common mistakes

Devices on the general network
Vendor modems always on
Disks leaving with old machines

How do we stop staff looking at records they do not need?

Short answer: Role access, flags and weekly log review

Snooping on VIP, celebrity, colleague or neighbour records is a common problem. Give access by role, mark sensitive records, ask for a reason before opening them, allow break-glass access in emergencies, and review those logs every week.

What the law says

Rule 6 requires access control and monitoring. Section 8(5) · Rule 6 · Section 8(6) · Rule 7

Steps

Flag VIP, staff and sensitive records.
Ask for a reason to open them.
Allow break-glass with review.
Review logs weekly.
Act on misuse consistently.

Evidence to keep

Flag settings
Review records
Action records

Common mistakes

Everyone can see everything
Break-glass never reviewed
No action on misuse

Something has gone wrong. What happens in the first 72 hours?

Short answer: Six hours for CERT-In; without delay for people and the Board; 72 hours for the detailed report

Contain it, then tell people. A reportable cyber incident goes to CERT-In within six hours of being noticed. Under DPDP, each affected person and the Data Protection Board must be told without delay, and the Board needs a detailed report within 72 hours. Sector regulators may have their own clock too.

From your seat: Information security / SOC department. Start the CERT-In clock and tell the DPO at once.

Example in Healthcare

A ransomware attack on the HIS needs a CERT-In report in six hours and the DPDP messages.

What the law says

Section 8(6) and Rule 7 set the DPDP steps. The CERT-In Directions of 28 April 2022 set the six-hour report. A breach includes accidental disclosure and loss of access, not only hacking. Section 8(6) · Rule 7 · Section 8(5) · Rule 6

Steps

Name one incident lead and a back-up, with phone numbers that work at night.
Write the first-hour steps: isolate, preserve logs, tell the DPO and the incident lead.
Keep ready-made drafts for CERT-In, the regulator, the Board and affected people.
Decide in advance who signs off each message.
Rehearse once a year with the people who would actually be called.

Evidence to keep

Incident plan with clocks
Rehearsal record
Incident log with times of each step

Common mistakes

Waiting to finish the investigation before telling anyone
Treating a wrong email or a lost laptop as 'not a breach'
Only IT knowing the plan

Which logs must we keep, for how long, and where?

Short answer: At least one year; 180 days of ICT logs in India

Keep logs that show who accessed personal data and what they did, for at least one year under the DPDP Rules. CERT-In separately asks for ICT system logs to be kept for 180 days within India. Logs must be protected so nobody can quietly change them.

From your seat: Information security / SOC department. One year of access logs, 180 days of ICT logs in India.

Example in Healthcare

HIS and PACS access logs show who opened which record; keep them a year.

What the law says

Rule 6 lists logs and monitoring as a minimum safeguard. Rule 8(3) asks for logs to be kept for at least one year. The CERT-In Directions of 2022 ask for 180 days of ICT logs kept within India. Section 8(5) · Rule 6 · Section 8(7) · Rule 8

Steps

List systems holding personal data and what each logs today.
Turn on access logging where it is missing.
Send logs to one protected store, with at least one year of retention.
Keep a copy of ICT logs in India for at least 180 days.
Sync clocks and review alerts every day.

Evidence to keep

Log source list
Retention settings
Alert review records

Common mistakes

Logging only failures, not who viewed a record
Logs stored on the same server they describe
Clocks out of sync, so timelines cannot be built

Who should be able to see personal data in our systems?

Short answer: Only those who need it, reviewed every quarter

Only people who need it for their job, and only the part they need. Use named accounts, give access by role, review it every quarter and remove it on the day someone leaves. Watch privileged accounts closely.

From your seat: Information security / SOC department. Watch privileged and vendor accounts.

Example in Healthcare

End shared ward logins; flag VIP and staff records.

What the law says

Rule 6 names access control as a minimum safeguard, along with logs and monitoring that can detect misuse. Section 8(5) · Rule 6

Steps

Write a role matrix for each key system.
Replace shared logins with named accounts.
Use multi-factor sign-in for admin and remote access.
Review access every quarter with each manager.
Remove access on the last working day.

Evidence to keep

Role matrix
Quarterly review sign-offs
Leaver removal report

Common mistakes

Generic logins on shared machines
Access that only grows
No review of vendor accounts

Does a security dashboard show privacy readiness?

Short answer: Only for the security part

Not by itself. A security dashboard shows alerts, patches and controls. It does not show whether notices were given, consent was recorded, requests were answered, vendors signed terms or data was deleted on time. Use it as evidence for the security duty only.

From your seat: Information security / SOC department. A green dashboard is not evidence of privacy readiness.

What the law says

Section 8(5) is one duty among many in Sections 5 to 12. Section 8(5) · Rule 6 · Section 5 · Rule 3 · Sections 11–14 · Rule 14

Steps

Map what the dashboard covers to Rule 6.
List the duties it does not cover.
Give those duties their own evidence.
Show both to management side by side.
Avoid one overall green status.

Evidence to keep

Coverage map
Evidence for other duties

Common mistakes

Reporting a green SOC dashboard as DPDP readiness
No owner for non-security duties
One colour for everything

Does deletion have to reach backups and test copies?

Short answer: Yes, through a written backup-expiry rule

Deletion should reach every copy you control. For backups, the usual practice is to let deleted records expire with the normal backup cycle, never restore them into live use, and write this down. Test and training copies should use masked data.

From your seat: Information security / SOC department. Test a full restore.

Example in Healthcare

Offline backups decide whether care continues during ransomware.

What the law says

Section 8(7) asks for erasure. Rule 6 asks for backups for continuity. The two meet in a backup retention rule that is short enough and written down. Section 8(7) · Rule 8 · Section 8(5) · Rule 6

Steps

List where copies live: backups, replicas, test, analytics, laptops, vendors.
Set backup retention to match the retention schedule.
Write a rule: deleted records are not restored into live systems.
Mask personal data in test and training copies.
Get deletion confirmations from vendors.

Evidence to keep

Backup retention settings
Written backup-expiry rule
Masking procedure for test data

Common mistakes

Ten-year backups for convenience
Live copies in test
Restoring old backups and bringing deleted records back

What must a vendor contract say about personal data?

Short answer: Yes, every vendor that touches personal data

You stay responsible for what your vendors do with personal data. The contract should say what data they get, for what purpose, the security they must keep, how fast they must tell you about an incident, that sub-contractors need your approval, and how data is returned or deleted at the end.

From your seat: Information security / SOC department. Monitor vendor access.

Example in Healthcare

Labs, teleradiology, HIS vendors, TPAs and ambulance services.

What the law says

Section 8(1) keeps responsibility with you. Section 8(2) allows a processor only under a valid contract. Rule 6 asks for security terms in that contract. Section 8(1)–(2) · Section 8(5) · Rule 6 · Section 8(6) · Rule 7 · Section 8(7) · Rule 8

Steps

List vendors who receive or can see personal data.
Rank them by how much and how sensitive.
Add a data-protection schedule to each contract, starting with the top ten.
Ask for evidence: certificates, test results, deletion confirmations.
Review the top vendors every year.

Evidence to keep

Vendor register
Signed data-protection schedules
Annual review notes

Common mistakes

Relying on the vendor's standard terms
No incident-notice time
No exit and deletion clause

Staff share personal data on WhatsApp and personal email. What do we do?

Short answer: Yes, this is a common breach; give staff a safer option

Sending personal data to the wrong chat or a personal account is one of the most common breaches. Banning messaging rarely works. Give staff an approved tool that is easy to use, set simple rules, and make it safe to report a wrong send at once.

From your seat: Information security / SOC department. Data-loss rules help; reporting routes matter more.

Example in Healthcare

Reports and images on WhatsApp groups are the most common hospital breach.

What the law says

Section 8(5) asks for reasonable safeguards. A wrong send is a breach under Section 2(u), and Section 8(6) applies. Section 8(5) · Rule 6 · Section 8(6) · Rule 7

Steps

Ask teams how they actually share files and photos today.
Provide an approved tool for that job.
Set three simple rules: approved tool, no personal accounts, report wrong sends.
Teach the rules with real examples from your own work.
Treat a quick report as good behaviour, not a disciplinary case.

Evidence to keep

Approved-tool policy
Training record
Incident reports of wrong sends

Common mistakes

A ban with no alternative
Punishing people who report
Ignoring group chats with vendors

Does ISO 27001 or NIST CSF cover our DPDP duties?

Short answer: They cover security, not the whole Act

They help a great deal with the security part. ISO/IEC 27001 and NIST CSF 2.0 are good evidence of reasonable security safeguards. They do not cover notice, consent, rights, complaints or children's data. ISO/IEC 27701 adds privacy controls, but no certificate replaces the Act.

From your seat: Information security / SOC department. Map controls once.

Example in Healthcare

NABH information management standards and ISO 27001 support Rule 6.

What the law says

Section 8(5) and Rule 6 ask for reasonable security safeguards. A recognised standard is strong evidence of that duty, and only of that duty. Section 8(5) · Rule 6

Steps

Map your current controls to Rule 6.
Add the DPDP-only items: notice, consent, rights, complaints, children, retention.
Use the same evidence for audits and for DPDP.
Include privacy in the scope of your next internal audit.
Consider ISO/IEC 27701 if clients ask for it.

Evidence to keep

Control map
Audit reports
Gap list for DPDP-only items

Common mistakes

Treating a certificate as DPDP compliance
Scope that leaves out the systems with the most personal data
No owner for the non-security duties

The sections you will use most

Section 8(5) · Rule 6: Security safeguards. HIS, PACS, lab systems and shared workstations need access control and logs.
Section 8(6) · Rule 7: Telling people about a breach.
Section 8(7) · Rule 8: Erasure and retention.

Other rules that sit alongside DPDP

Rule	What it says	What it means alongside DPDP	Source
Indian Medical Council (Professional Conduct, Etiquette and Ethics) Regulations, 2002	Regulation 1.3.1: keep indoor patients' medical records for 3 years from the start of treatment. Regulation 1.3.2: issue records to patients, authorised attendants or legal authorities within 72 hours of a request. Regulation 2.2: keep patient confidences.	Set retention at or above these minimums. Use the 72-hour record copy rule as the base for patient access requests.	Code of Medical Ethics, 2002
Telemedicine Practice Guidelines, 2020 (Appendix 5 to the 2002 Regulations)	Consent is implied when the patient starts a teleconsultation and must be explicit when a health worker or caregiver starts it. The doctor records consent and keeps logs, records and prescriptions as for in-person care.	Telemedicine apps must add DPDP notices and protect chat, video and prescription data.	MoHFW
Pre-Conception and Pre-Natal Diagnostic Techniques (PCPNDT) Act, 1994	Records of tests and procedures, including Form F, must be preserved for 2 years, or until a legal proceeding ends.	These records cannot be erased early on request; protect them carefully.	Tamil Nadu health department FAQ
Medical Termination of Pregnancy Regulations, 2003	The admission register is a secret document, kept by the head of the hospital, not open to inspection except under law, and kept for five years.	MTP records need the tightest access in the hospital.	MTP Regulations
Mental Healthcare Act, 2017	Section 23: right to confidentiality. Section 24: no photos or information to media without consent. Section 25: right to access basic medical records.	Psychiatry and counselling records need separate access and a careful request process.	NHSRC copy of the Act
HIV and AIDS (Prevention and Control) Act, 2017	HIV status may be disclosed only with informed consent, except in narrow cases. Establishments keeping HIV-related records must adopt data protection measures.	Restrict HIV results and counselling notes to the treating team.	Act
New Drugs and Clinical Trials Rules, 2019	Informed consent of trial participants; ethics committees keep records for five years after the trial ends (Rule 13).	Trial data needs both informed consent and DPDP safeguards.	NDCT Rules
Drugs Rules: Schedule H1 register	Pharmacies record prescriber's name and address, patient's name, drug and quantity, kept for three years.	Keep the register for three years, then dispose of it.	NHSRC
ABDM Health Data Management Policy	For entities in the Ayushman Bharat Digital Mission, health records are shared through a consent manager, with consent artefacts for each request.	If you are ABDM-linked, the ABDM consent flow and your DPDP notices must agree.	ABDM / NHA
Clinical Establishments Act, 2010 and Rules, 2012 (states that adopted it)	Registered establishments maintain medical records, and electronic records as the government specifies.	Check whether your state follows this Act or its own nursing home law.	MoHFW
IRDAI health insurance master circular, 2024	Insurers decide cashless requests within one hour and final discharge within three hours.	Fast TPA sharing is needed, but only the records the claim needs, through secure channels.	IRDAI
CERT-In Directions, 2022	Report specified cyber incidents within six hours; keep ICT logs 180 days in India.	A ransomware attack needs a CERT-In report and the DPDP messages.	CERT-In