Building a secured digital infrastructure


With National Digital Health Mission(NDHM), government envisions to improve digital health infra, facilitating quality and accessible healthcare services to people at large. Though objective seems to be right, there are challenges which need to be fine tuned to leverage it in best possible manner. Interoperability, data security are some of the key challenges. Here are viewpoints of our experts, who talk at length on various facets of NDHM.


Akash Karmakar, Partner, Law Offices of Panag & Babu :

The National Digital Health Mission attempts to create an integrated digital system whereby every Indian citizen will have unique health identifiers, which will be matched to their digitised health records. While it is an ambitious plan, it raises questions of data security, compulsion to register for yet another unique identity which is separate of the UIDAI’s purview, and expecting that digitization of health records can be done without building secure digital infrastructure.

While on one hand, unorganized health records often result in poor delivery of centralized healthcare services and poor consistency of government healthcare for the same person, if they relocate across India, it is this very data that becomes a prime target for data theft when structured and centralized owing to the value of such data.


There are two key concerns that people have with respect to the NDHM. Firstly, neither government nor private healthcare can be predicated on a person obtaining a unique health identifier. If this is the premise, no consents or data ‘voluntarily’ obtained would be free or informed since the person’s ability to access healthcare is being held ransom. Secondly, an additional identifier over and above the AADHAAR rather than being based on AADHAAR data is duplicative and raises questions about why the AADHAAR data is not being relied upon.

Also read: ‘NDHM will bring in integrated systematic healthcare infrastructure’

If the NDHM allows for inter-hospital data sharing, this should be permitted only for the purpose of treating a person enrolled in the NDHM and for associated purposes (such as conducting pathological tests etc.). Such data should not be permitted for any other purpose. Even if anonymized, this data would retain its sensitive nature according to the non-personal data governance framework. Accordingly, there should be strict enforcement of the purpose limitation of such information, and other than for ‘view access’, ability to download this data on the device, rather than have this on a centralized cloud server, and sharing of such data should not be permitted to prevent misuse or leakage of such data.

The government will inevitably have to set up telemedicine centres where traditional healthcare services are scarce or there is a skewed doctor-patient ratio. While there has been low broadband internet penetration, most of India has wireless internet coverage and the ubiquity of 3G and 4G cellular services has provided the last mile connectivity which traditional brick and mortar infrastructure has failed to do. Relying on the digitization of health records (especially when most patients have to go to larger cities for complex treatments) is the only way that last mile healthcare infrastructure can be achieved, albeit with telemedicine.

Charu Sehgal, Partner and Life sciences and Healthcare Industry Leader, Deloitte India

The launch of NDHM can be a very significant development in moving India’s Healthcare to the next level. Apart from the obvious advantage of convenience for the patient, given that s/he will not need to store and carry old records, it will be a boon for those who relocate for work. Given that remote doctor consultation will continue even after the pandemic ends, the digital access to patient data can be a game-changer leading to a more effective diagnosis. Most importantly, this will improve access by providing a big boost to consultation through telemedicine with specialist doctors for patients in smaller towns and remote locations. Providing a unique identification to doctors as well as health facilities can lead to streamlining several issues of quality and accountability. Data confidentiality will of course need to be ensured.”

Anupama Joshi, Partner, Deloitte India

The announcement of the National Digital Health Mission including a unique health ID card for every citizen is a well-timed and welcome move. It has the potential of changing the way healthcare is accessed in the country putting the consumer at the centre and in control. Traditionally healthcare has been lagging behind in its digital footprint as compared to other consumer sectors such as e-commerce and often this has been due to the resistance within the healthcare community. The COVID-19 has accelerated the journey towards digital healthcare bringing great opportunities to telemedicine, home healthcare, e- pharmacies, home collection etc. The government has facilitated this journey with its issue of telemedicine guidelines during the pandemic and its opportune partnerships with health start-ups, health IT firms and healthcare providers across the country for fighting against the pandemic.

While the government has announced an opt in policy for citizens as well as healthcare service providers, the success of India’s digital healthcare journey will be marked by the ability of the government to ensure the announcement and roll out of well understood data protection policies governing privacy of patient data. It will also have to ensure that data storage is cyber secure and increasing number of non-government hospitals, diagnostics firms, pharmacies, home care and other non-traditional providers find a great value proposition in coming on Board India’s digital healthcare platform.

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