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Consultation Paper on Proposed Health Data Retention Policy
Medical Councils (Central/ State)
Licensing and Certification Authorities
Private Insurance Companies and Third-party Administrators
Public Sector/ Government Authorities/ Offices
Private Companies/ Organisations
Non-Profit Organisations/ Foundations/ Trusts
Consumer Advocacy Groups
Note: Files must be less than 20MB; Allowed file format: PDF only
Please respond to the following individual questions as raised in the Consultation Paper on Proposed Health Data Retention Policy. Refer to the corresponding chapter/ section numbers to read the full text.
1. Whether there is a need for a Health Data Retention Policy and will Indian healthcare ecosystem benefit from such a Universal Data Retention Policy and what should be the key elements of this policy?
2. How should the guiding principle of this policy be determined for the benefit of stakeholders and ease of adoption by varying sizes of entities deciding to opt in for ABDM?
1. With reference to 3.1.3 As per Option 1, it has been proposed that the policy would be applicable to all healthcare entities from health data retention perspective. As per Option 2, the policy will be applicable only to entities participating in ABDM? Which would be a better option for the scope of the health data retention policy?
2. How such a policy should be implemented given limitations in terms of infrastructure, capability, and sufficient understanding of health data in the healthcare ecosystem?
3. As ABDM has a provision for opt-out, in such a scenario what may be the possible implications from the perspective of health data retention?
1. Should a blanket retention duration be adopted for all health records in India or different schedules be defined as per a classification? Which is a better approach of retention?
2. How granular should data classification be? Is more granularity required beyond that presented in the sections above? Addressing this aspect of the Health Data Retention Policy would help assess whether minimalist data classification – pertaining only to inpatients and outpatients - would suffice the purpose of health data retention. A minimalist data classification would have both advantages and disadvantages. Please suggest your view in this regard.
3. How in your view will a detailed granular data classification enable a better health data retention? Please suggest your view on the classification of health record types as proposed above or if any further granularity is necessary and what are the overarching benefits for different stakeholders?
4. What should be the ideal duration for these different health data types?
5. While ABDM proposes that all entities opting to join NDHE must be able to retain health data in electronic format, and other entities of the healthcare ecosystem may consider physical or original formats, what options should be made allowable 38 as part of the policy being proposed? Health data records can be only digital, only physical, or combination in any hospital. Accordingly, the question arises whether all the above considerations should fall under one policy or under separate/independent policies?
6. Should there be a provision for extension of duration or retention of health data under the policy being proposed? What considerations should be made in defining the guidelines, allowing for such an extension?
7. Who shall have the apex authority to oversee and implement health data retention? Which entity as part of the ecosystem should be rolling out this policy at the macro-level?
8. How can smaller clinics or centres, both public and private, build capability in a timely and cost-efficient manner to take responsibility of data retention for long time periods?
9. How can business continuity be ensured in case of fall of the establishment, platform or service providers?
1. Will the governance model as per Health Data Management Policy be sufficient for the retention policy?
2. How will the policy regulation be enforced and what should be the structure across relevant entities responsible for retaining the health data?
3. How should the implementation of the policy be done in case the policy is made applicable for the ecosystem beyond ABDM?
4. Is there an alternative model or policy approach which could be considered?