Sujeet Katiyar is a seasoned leader with over 27 years of experience in technology, healthcare, and regulatory compliance. His work bridges the complex worlds of digital health, data privacy, and policy, with hands-on expertise in implementing frameworks like the Digital Personal Data Protection Act (DPDPA), GDPR, HIPAA, and ABDM. From navigating patient data protection in clinical settings to shaping governance for emerging health technologies, Sujeet has built a career on ensuring that innovation and compliance grow hand in hand. His insights are grounded in real-world application, making him a trusted voice for organizations seeking to balance regulatory readiness with operational efficiency.
Who is Sujeet Katiyar?
Sujeet Katiyar is a healthcare compliance advisor, privacy strategist, and technology leader who has worked extensively across India’s health-tech and regulatory ecosystem. His expertise spans privacy-by-design implementation, ABDM integration, SaMD compliance, and cross-border data governance. Known for translating complex legal requirements into practical workflows, Sujeet advises hospitals, diagnostics networks, health-tech startups, and policymakers on building secure, compliant, and patient-centric systems. He brings a rare combination of technical depth, legal understanding, and healthcare domain knowledge to every engagement.
Q1. With over 27 years in technology, healthcare, and compliance, what inspired your focus on data privacy and laws like DPDPA, GDPR, and HIPAA?”
Sujeet: My journey into data privacy began at the intersection of technology and healthcare, where I witnessed firsthand how sensitive personal and health data was being generated, stored, and shared at an unprecedented scale. Over the years, I saw how gaps in governance, lack of awareness, and inadequate safeguards could lead to not only regulatory penalties but also erosion of patient trust, something that is far more difficult to rebuild. This real-world exposure made me realize that compliance is not just a legal necessity; it’s a cornerstone of ethical, sustainable business in healthcare.
Frameworks like the DPDP Act, GDPR, and HIPAA are, to me, more than regulatory checklists, they are essential guides to building trust, enabling secure digital transformation, and protecting one of the most valuable assets in healthcare that is patient data. My focus on these laws comes from a conviction that robust data privacy practices empower innovation, protect individual rights, and create a competitive advantage for organizations that prioritize them from the inside out.
Q2. What do you like most about DPDPA?
Sujeet: What stands out in the DPDP Act is its strong emphasis on informed consent and purpose limitation, which is vital in healthcare where sensitive medical data demands the highest protection. It mandates that patient data be processed only for clearly defined purposes, ensuring both legal compliance and patient trust.
Equally important is the accountability framework for Significant Data Fiduciaries, requiring DPO appointments, DPIAs, and robust security backed by penalties of up to ₹250 crore for violations. This not only aligns with GDPR and HIPAA standards but also compels healthcare entities to adopt privacy-by-design, safeguarding both patients and institutional credibility.
Q3. What do you dislike most about DPDPA?
Sujeet: One concern with the DPDP Act is the absence of a clear, enforceable framework for compensation to Data Principals in cases of proven harm due to data breaches, which limits effective remedies for patients impacted by mishandling of sensitive health data.
Another limitation is the broad exemptions granted to the State, which, if not narrowly interpreted, may override patient privacy safeguards and dilute trust in digital healthcare systems. Additionally, the lack of sector-specific guidance for healthcare leaves room for inconsistent interpretation, increasing compliance uncertainty for hospitals, insurers, and healthtech providers.
Q4. In your view, what lessons from global laws like GDPR and HIPAA should India adopt to ensure DPDPA’s enforcement is effective and business-friendly?
Sujeet: From the GDPR framework, India should adopt the principle of “privacy by design and by default”, making it mandatory for healthcare entities whether hospitals, diagnostic centers, or telemedicine platforms to integrate data protection controls at every stage of system and process development. This would ensure that Electronic Health Records (EHR), AI-driven diagnostics, and wearable health technologies are designed to minimize data collection, restrict access, and prevent breaches proactively rather than reactively.
From HIPAA, the robust breach notification and accountability mechanisms should be emphasized, requiring clear timelines, detailed disclosures, and mandatory remediation steps in the event of a health data breach. Combining this with sector-specific codes of practice for healthcare under the DPDP Act would ensure that compliance is not just punitive but also business friendly, helping healthcare providers maintain patient trust while avoiding operational disruptions and penalties.
Q5. How does Fourteenth Degree Azimuth approach DPDPA compliance differently for mid-market and regulated sectors like healthcare?
Sujeet: At Fourteenth Degree Azimuth (India) Advisory, our approach to DPDP Act compliance is highly contextual tailored for the operational realities of each client. For mid-market healthcare organizations like standalone hospitals, diagnostic chains, and digital health startups, we focus on creating scalable, cost-effective compliance frameworks that prioritize immediate risk areas without overburdening resources. This includes simplified consent management, phased data mapping, and targeted training to embed privacy in daily operations.
For regulated healthcare sectors including large hospital networks, pharmaceutical firms, insurance providers, and ABDM-integrated platforms we adopt a rigorous, audit-led compliance model aligned with both domestic law and global frameworks like GDPR and HIPAA. This means integrating DPDP requirements with other sector mandates such as Telemedicine Practice Guidelines, Medical Devices Rules, and ABDM specifications.
By combining legal expertise, sector-specific knowledge, and hands-on technology guidance, we deliver end-to-end solutions where compliance becomes a strategic advantage building trust, enhancing operational efficiency, and protecting brand credibility in India’s rapidly evolving healthcare landscape.
Q6. How should hospitals and diagnostic networks interpret DPDPA’s consent, notice, and purpose limitation requirements in real clinical workflows like admission, teleconsults, and home collection?
Sujeet: Hospitals and diagnostic networks should treat the DPDP Act’s consent, notice, and purpose limitation requirements as core patient touchpoints rather than mere legal formalities. At admission whether in-person or via teleconsult platforms, patients must be provided with clear, specific, and easily understandable notices explaining what personal and sensitive health data will be collected, why it is needed, how it will be used, and with whom it will be shared. Consent should be free, informed, and recorded, ideally through digital or written formats integrated into hospital information systems.
For teleconsultations and home collections, workflows should embed real-time consent prompts for activities such as recording consultations, sharing reports with third parties, or using data for analytics. Under the purpose limitation principle, data collected for diagnosis or treatment cannot later be repurposed for example, for marketing without obtaining fresh consent. Embedding these requirements into clinical processes not only ensures legal compliance but also strengthens patient trust, reduces liability risk, and aligns with global healthcare privacy standards.
Q7. What’s the best way to align DPDPA consent managers with ABDM’s consent flows in hospitals and diagnostics?
Sujeet: The most effective approach to align DPDP Act consent managers with ABDM’s consent flows is to establish an interoperable, standards-based consent architecture that satisfies both legal and technical requirements. Hospitals and diagnostic networks should integrate DPDPA-compliant Consent Managers, registered with the Data Protection Board, into their ABDM-enabled systems so that a single consent capture process meets the obligations under both frameworks.
Legally, this requires that the consent artefacts generated under ABDM’s Health Information Exchange and Consent Manager (HIE-CM) specifications also fulfil DPDPA’s statutory requirements namely, being free, informed, specific, unconditional, and revocable while maintaining immutable audit trails. Operationally, mapping ABDM’s health-data exchange purposes to DPDPA’s purpose limitation clauses ensures there is no conflict or overreach, thereby creating a unified, regulator-proof consent workflow across care delivery, diagnostics, and health data sharing.
Q8. What clarifications or rules would you most like to see in DPDPA to make healthcare adoption easier and safer?
Sujeet: To make DPDPA adoption in healthcare both easier and safer, two clarifications are critical.
First, sector-specific guidance on retention and deletion timelines for health data is essential. In clinical contexts whether hospital admissions, diagnostics, or chronic care premature deletion can compromise patient safety, while over-retention heightens breach and liability risks. Legally sanctioned timelines that align with treatment cycles, statutory record-keeping, and medico-legal obligations would ensure consistency, reduce disputes, and strengthen compliance confidence.
Second, the Act should provide clear rules on lawful bases beyond consent for scenarios like medical emergencies, public health reporting, and research, coupled with an enforceable framework for compensation in cases of proven harm due to breaches. This would balance flexibility with accountability, close a critical patient rights gap, and align with the Act’s strong consent and purpose-limitation principles ultimately building trust while maintaining operational agility in India’s healthcare ecosystem.
Q9. How can AI be used not just to comply with DPDPA, but to actually improve privacy outcomes across departments?
Sujeet: The DPDP Rules explicitly require that algorithms and automated decision-making tools used in processing personal data be auditable, explainable, and free from discriminatory bias. By leveraging privacy-aware AI, hospitals and diagnostic networks can deploy explainable algorithms for consent management, de-identification, and controlled data sharing across departments. This not only meets algorithmic transparency requirements but also builds patient trust positioning AI as a strategic enabler for stronger privacy outcomes across clinical, administrative, and research functions.
Beyond compliance, AI can embed privacy-by-design into everyday operations. For example, AI-driven data classification and minimization can ensure that only the minimum necessary patient information is accessed for a specific workflow supporting the DPDP Act’s purpose limitation mandate. AI can also continuously monitor access patterns to detect unusual or unauthorized data use, thereby enhancing both compliance and data security while reducing the risk of breaches caused by human oversight.
Q10. Looking ahead, what privacy or security challenge do you think will define the next decade for Indian enterprises?
Sujeet: Over the next decade, a key privacy challenge for Indian enterprises will be balancing interoperability with data minimization, sharing enough information for operational efficiency while limiting it to the minimum necessary to remain compliant with laws like the DPDP Act. Another major challenge will be securing AI-driven ecosystems. As enterprises increasingly deploy AI for decision-making, ensuring algorithmic transparency, bias prevention, and auditability as required under the DPDP Rules will be essential. Coupled with an evolving cybersecurity threat landscape, from ransomware to targeted data breaches, this will demand robust zero-trust frameworks and continuous monitoring to safeguard both compliance and stakeholder trust.
Q11. If you could change one thing about how Indian companies approach DPDPA readiness, what would it be?
Sujeet: If I could change one thing about how Indian companies approach DPDPA readiness, it would be to treat it as an enterprise-wide governance priority rather than an IT compliance checklist. Too many organizations, even large ones, still assume DPDPA is ‘an IT team’s job’ when in reality it cuts across legal, HR, operations, marketing, procurement, and customer-facing functions. The law’s consent, purpose limitation, and breach notification requirements demand integrated workflows, not siloed fixes.