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Privacy-by-Design Policy

Privacy by design

The principles Vitaloop builds to, so that privacy is part of how the platform works rather than a layer added afterwards. Structured around the six points the ABDM Health Data Management Policy asks data fiduciaries to publish.

Version 1.0Last updated 21 September 2026Platform status: pre-launch
Status: pre-launch

The Vitaloop hospital platform is under development and has no live hospital deployments at present. This policy states the principles we build to and the commitments we will be held to at launch. It describes design intent, not certification. We will update it as the platform is released, and say plainly what is live and what is still planned. Our current regulatory position is on the ABDM & regulatory status page.

The ABDM Health Data Management Policy asks data fiduciaries to publish a privacy-by-design policy that covers six things. Hospitals will be the data fiduciaries for their patients, and Vitaloop their data processor and software provider, so this page sets out both what the platform does for hospitals and what we hold ourselves to. It is separate from our Privacy Policy, which covers this website.

1. Practices and systems designed to avoid harm

The platform is designed so that the safe behaviour is the default one.

2. Obligations of data fiduciaries, and how the platform helps

Each hospital, as data fiduciary, is responsible for giving patients a clear notice, obtaining valid consent, limiting use to the stated purpose, keeping and erasing records on a lawful schedule, protecting the data, handling patients’ requests, and reporting breaches. The platform is designed to give hospitals the tools to do this:

What Vitaloop commits to as processor. We process patient data only on the hospital’s documented instructions; keep it confidential; bind every sub-processor to equivalent obligations in writing and tell the hospital before we add one; help the hospital answer patients’ requests; tell the hospital without delay if we become aware of a breach; and return or delete the data when the contract ends.

3. Technology and standards

We prefer open, widely used standards. We do not claim certification against any standard unless we hold it; see the status page.

AreaWhat we use
Health data exchangeHL7 FHIR R4, following the ABDM profiles published by NRCeS; ABDM open APIs and the ABDM consent manager
Clinical codingSNOMED CT, LOINC and ICD-10
Encryption at restAES-256 with envelope encryption under a managed key service, with separate data keys for each hospital
Encryption in transitTLS 1.3, with deprecated cipher suites disabled
Health information sent over ABDMEncrypted end to end using ECDH over Curve25519 with AES-256-GCM, following the Fidelius specification
AuditAppend-only audit trail modelled on ISO/TS 27789, with a separate disclosure log
Sign-in and accessNamed accounts, no shared credentials; multi-factor authentication for administrative and privileged roles; session idle and absolute timeouts

The platform is designed for two deployment models: multi-tenant cloud, and installation on a hospital’s own infrastructure. In the cloud model, patient data is designed to be stored and processed only in India, in the AWS Asia Pacific (Mumbai) region, with any backup copies also kept in India and encrypted. Where a hospital hosts the platform itself, the hospital operates the infrastructure and we supply a security baseline as installer defaults.

4. Protection from collection to deletion

StageWhat we do
CollectOnly what the clinical or administrative purpose needs. Notice first, then consent where consent is the basis.
UseOnly for the purpose the patient was told about. Identifiable data is not used for advertising, and is not sold.
ShareOnly with the patient’s consent, or where a law requires. Through ABDM, each release is tied to a consent artefact and logged. When a consent expires or is revoked, display stops and copies held by the recipient are deleted.
StoreIn India. Encrypted. Backups follow the same rules as live data.
KeepFor the longest period any applicable rule requires for that kind of record. Examples: inpatient records for at least three years; records of a termination of pregnancy for five years; a child’s record until the child turns eighteen. Legal holds override the schedule.
EraseWhen the period ends and no law or proceeding requires the record, it is erased, including from backups on their next rotation. A refusal to erase must say which record class, which law, and the earliest date erasure could happen.

5. Transparent processing

6. The patient’s interest at every stage

Governance

Nihar Bholane is Vitaloop’s Data Protection Officer and Grievance Officer (shobhit@vitaloop.in). This policy is reviewed at least once a year, and whenever the law, the product or the way we deploy it changes materially.