Legal · India DPDP Act, 2023 Compliance
Privacy policy & DPDP Act notice
Maarga helps doctors document clinical consultations with speed and accuracy. With the patient's explicit consent, the doctor records the consultation in the app or web console; Maarga transcribes the conversation and drafts a structured clinical note that the doctor reviews, edits, and signs.
1. Roles under the DPDP Act, 2023 (Data Fiduciary & Data Processor)
Under India's Digital Personal Data Protection Act, 2023 (DPDP Act):
- Data Fiduciary (Your Clinic or Hospital): The treating doctor, clinic, or hospital determines the purpose and means of processing patient health records and obtains informed patient consent before recording a consultation.
- Data Processor (Maarga Health): Maarga processes personal data strictly on behalf of and under the instructions of the Data Fiduciary (Section 8) solely to provide clinical documentation, longitudinal charting, and patient continuity tools.
- Data Principal (Patients & Clinicians): Patients and clinicians hold statutory rights to itemized notice (Section 5), consent withdrawal (Section 6(4)), correction and erasure (Section 12), and grievance redressal (Section 13).
2. Itemized notice of personal data collected & purpose (Sections 5 & 6)
| Category of Personal Data | Specific Purpose of Processing |
|---|---|
| Clinician's name, medical registration, specialty, and email address | Account authentication, tenant isolation, and medico-legal attribution on signed clinical notes and prescriptions. |
| Patient demographics entered by the clinic (name, age or date of birth, sex, MRN chart ID, optional phone number, optional ABHA ID) | Maintaining the clinic's longitudinal patient chart, ABDM health record linking (when consented), and issuing signed Patient Care Cards. |
| Ambient consultation audio recorded with explicit patient consent | Speech-to-text transcription and clinical note drafting. Raw audio is never used to train public AI models. |
| Transcripts, SOAP clinical notes, vitals, biomarker trends, prescriptions, attached lab reports, and bounded pre-visit symptom check-ins | Providing the clinic's electronic medical record and the patient's read-only Digital Care Card. |
| Service telemetry and security audit logs | Enforcing tenant isolation, detecting unauthorized access, and maintaining clinical accountability (contains no advertising identifiers). |
We do not run advertisements, broker or sell personal data, or track users across third-party apps or websites.
3. Data security & strict tenant isolation (Section 8(5))
To prevent unauthorized access and ensure one user or clinic can never access another user's or clinic's private data, Maarga enforces multiple technical and organizational safeguards:
- Strict Multi-Tenant Isolation: Every clinic and clinician account is bound to a cryptographically verified tenant scope (
hospital_idanduser_id). Every API endpoint, database query, document vault path, and audio stream verifies tenant ownership before returning or modifying any record. Cross-tenant access attempts are rejected with HTTP 403/404 and logged. - Encryption in Transit and at Rest (Mumbai Cloud Residency): All clinical records, transcripts, and audio files are stored on encrypted cloud infrastructure in Mumbai, India (AWS ap-south-1) using AES-256 encryption at rest and TLS 1.3 in transit.
- Signed Read-Only Patient Care Links: Patient Care Cards use 90-day HMAC-SHA256 cryptographic signatures bound to a specific consultation and hospital scope, with bounded numeric pre-visit inputs so completed clinical notes can never be altered after signing.
- Device-Level Keychain Encryption: Offline records on mobile and desktop devices are stored in an encrypted SQLite database protected by the operating system keychain.
4. Data deletion, right to erasure & consent withdrawal (Sections 6(4) & 12)
Personal data is retained only as long as necessary to fulfill the clinical purpose or comply with applicable Indian medical record retention laws. You can delete data at any time through built-in self-service controls:
- Delete an Individual Consultation & Purge Audio: In the Maarga Clinician Console (
/app) or mobile app, open any consultation and select Letters & export > Delete consult & purge audio. This immediately deletes the consultation record, transcript, and stored audio file from active storage. - Erase an Entire Patient Chart (Right to Erasure): In the patient chart pane of the Clinician Console, click Erase patient chart & data (or Delete empty chart). This permanently erases the patient's chart, all associated consultations, vitals, uploaded documents, and audio recordings.
- Patient Consent Withdrawal on Digital Care Card: Every Patient Care Card (
/care) includes a self-service Withdraw Consent / Request Data Erasure button. Submitting this request generates a timestamped DPDP Erasure Reference ID, clears local preview state, and notifies the treating clinic and Maarga's Data Protection Officer to complete erasure. - Clinician Account Deletion: A doctor can delete their account in the app (Settings > Account > Delete account) or by emailing privacy@maargahealth.com.
- Automatic Audio Expiry: Consultation audio is automatically purged 365 days after recording unless deleted earlier by the clinician or patient request.
5. Data breach notification protocol (Section 8(6))
Maarga maintains continuous security monitoring and an incident response protocol aligned with Section 8(6) of the DPDP Act, 2023 and CERT-In directives:
- Immediate Containment & Forensic Audit: Upon detecting any unauthorized access, disclosure, alteration, or loss of personal data, our security team immediately isolates affected credentials or endpoints and preserves forensic audit logs.
- Notification to the Data Protection Board of India (DPBI) & Affected Users: In the event of a personal data breach, Maarga notifies the Data Protection Board of India (DPBI), the affected clinic (Data Fiduciary), and each affected Data Principal (clinician and/or patient) without undue delay and within 72 hours (or such stricter timeline prescribed under DPDP Rules).
- Contents of Breach Notice: Every notification clearly states: (a) the nature, timing, and categories of personal data involved; (b) the likely consequences for the affected Data Principal; (c) the remedial and technical measures taken by Maarga to mitigate risk; and (d) direct contact details of our Data Protection & Grievance Officer for assistance.
6. Data Protection & Grievance Officer (Section 13)
For any questions, consent withdrawal, data erasure requests, or privacy grievances under the DPDP Act, 2023, please contact our designated Grievance Officer:
- Designation: Data Protection & Grievance Officer, Maarga Health
- Email: privacy@maargahealth.com / hi@maargahealth.com
- Location: Maarga Health, Bengaluru, Karnataka, India
- Resolution Timeline: All DPDP rights requests and grievances are acknowledged within 24 hours and resolved within the statutory timeline prescribed under the DPDP Act, 2023. If a Data Principal is unsatisfied with the resolution, they have the right to approach the Data Protection Board of India (DPBI).