DPDP Act compliance

DPDP Act compliance for hospitals and healthcare: what changes by May 2027

Hospitals, clinics, diagnostic labs, pharmacies, telemedicine and health-tech apps handle patient records, prescriptions, lab reports, insurance details and CCTV. Here is what the DPDP Act means for you and what to fix first.

188 days to the DPDPA compliance deadline (13 May 2027)See the 2027 roadmap →
Quick answer

Hospitals, clinics, labs and health-tech platforms are Data Fiduciaries under the DPDP Act and must comply by 13 May 2027. Health data has no separate 'sensitive' category, but its volume and sensitivity can lead the government to notify large providers as Significant Data Fiduciaries. Key duties: a clear notice at registration, consent or a legitimate use (medical emergencies are one), strong security, 72-hour breach reporting, and parental consent for under-18 patients outside the Fourth Schedule exemption for clinical establishments.

Deadline
13 May 2027
Emergency treatment
Legitimate use, no consent needed
Children (clinical care)
Fourth Schedule exemption
Likely SDF?
Large chains and platforms

Where hospitals and healthcare face the most DPDP risk

DPDP risk areas for hospitals and healthcare
AreaWhat to do
Patient registration and recordsNotice at the front desk and in the app; consent for anything beyond treatment (e.g. marketing health packages)
Lab reports on WhatsApp and emailEncryption or secure links, correct recipient checks, breach plan for misdirected reports
Insurance and TPA sharingShare only what the claim needs; contracts with TPAs and insurers as fiduciaries or processors
Health-tech apps and wearablesPurpose-specific consent; no reuse of health data for ads; children's data rules
CCTV in wards and receptionNotice signage, access control, short retention

Other rules that apply alongside the DPDP Act

  • Telemedicine Practice Guidelines, 2020 and NMC rules on confidentiality
  • Ayushman Bharat Digital Mission (ABDM) Health Data Management Policy, for ABHA-linked records
  • Clinical Establishments Act and state rules on keeping medical records

Where another law sets a stricter or longer requirement, follow both: the DPDP Act does not override sector rules on retention or storage.

Six steps to comply

  1. Map patient data from registration to discharge, including labs, pharmacy, billing and insurance.
  2. Put a short notice at registration (paper forms count once digitised) and in the app.
  3. Separate treatment use from marketing; add an unticked opt-in for health camps and offers.
  4. Lock down report sharing: secure links, access logs kept for at least a year.
  5. Write a breach plan covering ransomware, the most common hospital incident.
  6. Set retention: keep medical records as medical and state rules require, delete enquiry data sooner.

Most DPDPA duties apply from 13 May 2027, with penalties up to ₹250 crore per breach. See the DPDPA 2027 roadmap and the DPDP compliance checklist.

Want it done for you? Our DPDP compliance service covers data mapping, notices, consent, vendor contracts, breach plans and staff training for hospitals, clinics, diagnostic labs and health-tech platforms.

Frequently asked questions

Does the DPDP Act apply to hospitals and clinics?

Yes. Any hospital, clinic, lab or health-tech platform that processes patients' personal data digitally is a Data Fiduciary and must comply by 13 May 2027.

Do hospitals need consent to treat patients' data in an emergency?

No. Section 7 allows processing without consent to respond to a medical emergency involving a threat to life or health, and for treatment during an epidemic or disaster.

Is health data 'sensitive personal data' under the DPDP Act?

The Act has no separate sensitive category. All personal data gets the same protection, but the sensitivity of health data is a factor in notifying Significant Data Fiduciaries and in setting penalties.

DPDP guides for other industries

See all deadlines on the compliance calendar, or browse the compliance hub.

This guide is general information based on the law as of 25 October 2026, not legal advice. Rules and dates can change by notification; speak to a professional about your situation.

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