Health ID — Digital, Secure, Inclusive
The editorial in Business Standard dated October 4, 2021, titled “Digital Health ID concerns”, seems to be written with incomplete understanding of the architecture and design of the Ayushman Bharat Digital Mission (ABDM). In the spirit of ensuring public awareness and discourse, the National Health Authority (NHA) would like to take the opportunity to help correct some omissions and factual errors that have been made in the editorial. Given the critical importance of health in everyone’s lives, we feel it is essential to accurately represent the nature and design of ABDM in public interest.
It is stated in the editorial that the Health ID was assigned to anyone who provided Aadhaar to sign up on COWIN, by “default”.
This is unfortunately incorrect. A due process providing information and seeking consent is followed to create Health IDS. First, the purpose is explained in the terms of use while signing up on COWIN, explicit consent is obtained at the vaccination site, and the signup is verified using Aadhaar authentication. Additionally, eight other options for identification are made available other than Aadhaar for registration on the COWIN portal. This can barely be said to be the consent “taken in fine print”. Even then, only a Health ID is assigned (displayed clearly on their certificate).
In addition, individuals still need to link health records to it. ABDM already offers the ability for users to ‘opt-out’ of Health ID if they do not wish to use it, which the editorial recommends be provided in the future. Sufficient measures have been put in place that it is not possible for an individual’s health ID to be actively used or health records to be linked without their consent. In spite of this design giving control and freedom to the individuals, it is curious to note that the editorial seems to suggest that privacy has been put at risk. That is hardly the case. There is no data or security risk here.
It is also incorrect to state that in the absence of specific personal data protection law, there are concerns about such digital systems. Firstly, the current legal framework as laid out in laws including the IT Act and various judgments of the Supreme Court including the Puttaswamy judgment provides the legal framework to proceed with the development of such a system. Furthermore, additional regulatory framework has been provided through the Health Data Management Policy, which has been devised after extensive stakeholder consultations. It may be noted that even otherwise many such digital systems, including in the private sector, are smoothly working and delivering desired services to citizens within the existing framework.
Finally, the decision to use this Health ID or link health records is subject to the discretion of each individual. There is another factual inaccuracy in the fact that “security features of the PHR servers … are quite hazy”, and that millions of individuals and multiple agencies seeking this data will expose it to leakages. With a federated architecture, no health records will be stored in a central repository, reducing the risk of a single hacked server leading to leakages.
Further even from such a federated storage, health records will be shared only with the consent of an individual. It is worrying to note that such a critical feature of the architecture has been omitted in the editorial. As has been experienced through CO-WIN, ABDM also embraces inclusivity as a core principle and will endeavour to ensure that beneficiaries in every corner of the country have a choice to join the ecosystem. Those who do not wish to participate in the ecosystem will continue to have unrestricted access to healthcare.
India has beaten expectations time and again with its capability in building population scale systems and processes in various domains, leapfrogging decades of progress in a matter of few years. ABDM holds the potential to empower citizens in accessing health. We, at the NHA, are eager for every individual of the country to share their thoughts, concerns, and aspirations on the mission as we take this vision forward.
With a federated architecture, no health records will be stored in a central repository, reducing the risk of a single hacked server leading to leakages