Second time’s not the charm: Health Data Management Policy misses the mark again

IFF wrote to the National Health Authority (NHA) as part of the consultation conducted for the Ayushman Bharat Digital Mission’s Draft Health Data Management Policy (“Draft policy"). Through our inputs, we have tried to highlight the existence of a weak legal foundation and inadequate preparatory groundwork; excessive delegation; a constricted digital consent, confidentiality and privacy framework; over-reliance on an Aadhaar-based authentication system; and, vague systems for anonymisation and de-identification, as well as the complete absence of strict access control requirements for personal health data.

This is a companion discussion topic for the original entry at