Protecting Personally Identifiable Information (PII) in Healthcare: A Deep Dive into DPDP Act 2023 and Global Privacy Laws

In the digital age, Personally Identifiable Information (PII) has become one of the most valuable—and vulnerable—assets. For healthcare stakeholders, protecting PII is not just a regulatory requirement but a moral obligation. With the enforcement of the Digital Personal Data Protection (DPDP) Act, 2023, and the DPDP Rules, 2025, healthcare organizations in India must prioritize safeguarding PII to avoid severe consequences. This article explores the importance of PII in healthcare, the risks of mishandling it, and how the DPDP Act aligns with global privacy laws like GDPR, CCPA, PDPA, and HIPAA.

What is PII and Why is it Critical in Healthcare?

PII refers to any information that can be used to directly or indirectly identify an individual. In healthcare, this data is particularly sensitive due to its personal nature and the implications of misuse. Below are some examples of PII specific to the healthcare sector:

Examples of PII in Healthcare:

1. Basic Identifiers: Name, date of birth, address, phone number, email ID.

2. Government-Issued Identifiers: Aadhaar number, PAN number, passport details, Social Security Number (SSN in the US).

3. Health Identifiers: Unique Health ID (ABHA number in India), insurance policy numbers, hospital registration IDs.

4. Medical Records: Lab reports, prescriptions, treatment history, diagnostic images (X-rays, MRIs).

5. Biometric Data: Fingerprints, retinal scans, voice recognition used for patient authentication.

6. Genetic Data: DNA sequencing data, hereditary disease history.

7. Financial Information: Credit card details used for bill payments, bank details linked to insurance claims.

8. Digital Health Data: Wearable device data (heart rate, blood sugar levels), app-based fitness tracking.

Importance of PII in Healthcare:

• Patient Trust: Protecting PII builds trust between patients and healthcare providers.

• Regulatory Compliance: Mishandling PII can lead to legal penalties under the DPDP Act, GDPR, or other laws.

• Operational Efficiency: Secure PII management ensures smooth healthcare operations, from telemedicine to insurance claims.

Risks of Mishandling PII in Healthcare

Failure to protect healthcare PII can lead to dire consequences, including:

• Identity Theft: Stolen health records can be used to create fake insurance claims or obtain medical services fraudulently.

• Operational Disruptions: Cyberattacks leading to downtime of hospital systems and telemedicine platforms.

• Medical Fraud: Fake prescriptions, misuse of insurance benefits, and phantom billing.

• Targeted Cyber Attacks: Hackers can exploit personal health information (PHI) for ransom demands or unauthorized drug purchases.

• Loss of Patient Trust: Data breaches lead to reputational damage for hospitals, insurers, and digital health platforms.

• Legal Consequences: Violating PII protection laws can result in hefty fines and penalties.

PII Under the DPDP Act, 2023, and DPDP Rules, 2025

The DPDP Act defines PII as “any data that can identify an individual” and mandates strict safeguards for its protection. Key provisions include:

• Consent: Explicit consent must be obtained before collecting or processing PII.

• Data Minimization: Only the necessary PII should be collected.

• Breach Notification: Data breaches involving PII must be reported to the Data Protection Board of India (DPBI) and affected individuals within 72 hours.

Healthcare Example: A hospital using telemedicine must obtain patient consent before collecting their name, phone number, and medical history. The data should be encrypted and stored securely, with access limited to authorized personnel.

Comparison of PII Protection Under Global Privacy Laws

GDPR (EU):

• Definition: PII includes any data that can directly or indirectly identify an individual.

• Healthcare Example: A European hospital must obtain explicit consent before processing patient data and report breaches within 72 hours.

CCPA (California, USA):

• Definition: PII includes names, addresses, medical information, and biometric data.

• Healthcare Example: A California-based telehealth platform must allow patients to opt-out of data sales and provide access to their PII upon request.

PDPA (Singapore):

• Definition: PII includes data that can identify an individual, such as NRIC numbers and medical records.

• Healthcare Example: A Singaporean clinic must notify the Personal Data Protection Commission (PDPC) in case of a data breach involving patient PII.

HIPAA (USA):

• Definition: PII in healthcare is referred to as Protected Health Information (PHI), including medical records and insurance details.

• Healthcare Example: A US hospital must implement safeguards like encryption and access controls to protect PHI.

Best Practices for Healthcare Organizations to Protect PII

1. Implement Data Encryption: Protect stored and transmitted patient data.

2. Adopt Access Controls: Restrict PII access to authorized personnel only.

3. Conduct Regular Audits: Ensure compliance with DPDP Act and other privacy laws.

4. Ensure Data Anonymization: De-identify patient data before analytics and AI processing.

5. Provide Staff Training: Educate employees on PII protection and cybersecurity threats.

6. Develop a Data Breach Response Plan: Prepare for potential cybersecurity incidents.

With the DPDP Act, 2023, and the upcoming DPDP Rules, 2025, Indian healthcare stakeholders including hospitals, health insurers, pharmaceutical companies, and digital health platforms—must proactively enhance their PII protection strategies. By aligning with global best practices such as GDPR, HIPAA, and CCPA, healthcare providers can ensure compliance, foster patient trust, and prevent financial and reputational losses.

The responsibility to protect PII in the digital healthcare ecosystem is no longer optional—it is a legal and ethical obligation. The time to act is now. Let’s work together to create a safer, more transparent healthcare ecosystem.