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Sector regulation

HDS v2 — French health data hosting certification

The certification required in France to host personal health data on behalf of third parties.

At a glance

Type
French regulatory certification
Publisher
Agence du numérique en santé (ANS)
Version
2.0 (2024)
Foundation
ISO/IEC 27001:2022 + 31 specific requirements

37 requirements tracked · 106 shared controls

What is HDS?

Article L.1111-8 of the French Public Health Code requires a certification for anyone hosting personal health data collected during prevention, diagnosis, care or social and medico-social follow-up, on behalf of a third party. The framework is published by the French digital health agency (ANS).

Version 2.0, approved by decree in 2024, builds on ISO/IEC 27001:2022 and adds 31 specific requirements: scope, subcontracting, customer information, hosting contract and reversibility, and sovereignty requirements (storage in the European Economic Area, control of access from third countries, a public map of transfers). Since 16 May 2026, every valid certificate attests compliance with v2.

Key requirements

  1. 1

    ISO 27001 ISMS covering hosting

    The management system must cover all the hosting activities in the certificate scope.

  2. 2

    ISMS additions

    Interested parties and legal framework, feared events specific to health data, allocation of responsibilities, internal audits.

  3. 3

    Hosting contract

    Clauses required by the Public Health Code, customer information and reversibility.

  4. 4

    Sovereignty

    Storage exclusively in the EEA, control of access from third countries, analysis of exposure to non-European laws, public map of transfers.

Summary written by OK-GRC. The texts of ISO standards are protected by copyright and are not reproduced.

How OK-GRC helps

  • HDS v2 requirements linked to 106 common controls, shared with your ISO 27001 ISMS
  • Supplier register with data location and transfer mechanisms
  • Supplier policy, cloud policy and data processing agreement templates
  • Evidence tracking, internal audits and management review for the certification audit

Frequently asked questions about HDS

Can we store patient data in OK-GRC?

No. OK-GRC is for managing your compliance (policies, risks, evidence, audits) and is not an HDS-certified host: do not upload personal health data to it.

Is ISO 27001 certification enough for HDS?

No. It is the mandatory foundation, but the HDS audit also checks the framework’s 31 specific requirements, in particular the contractual and sovereignty requirements.

Informational content up to date as of October 2026; it does not constitute legal advice. Always check the official texts in force.

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