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Disclosure | Family 3, Security, Privacy & Trust Disclosures
Read this before you sign, not before you go live. This document exists to prevent the most expensive surprise available in hospital software: discovering at cutover that a regulatory registration nobody obtained is on the critical path, and that it takes six weeks.
DIS-GL-024 v1.0.0, Last Modified On 31 July 2026, Tier: Public
Incorporates DIS-GL-026, ABDM / NHCX Responsibility Matrix (RACI), at Section 5.
Read this before you sign, not before you go live. This document exists to prevent the most expensive surprise available in hospital software: discovering at cutover that a regulatory registration nobody obtained is on the critical path, and that it takes six weeks.
| Deployment model | Applies | Variation |
|---|---|---|
DM-1 Dedicated |
Yes | None. The boundary is identical |
DM-2 Shared |
Yes | None |
DM-3 Customer Cloud |
Yes | Outbound network paths are governed by the hospital's own egress policy |
DM-4 On-Premise |
Yes | Outbound connectivity, firewall rules and internet availability are entirely the hospital's |
The boundary described in this document does not change by deployment model. Who holds a credential and
who is the regulated participant is a legal and architectural fact, not a hosting decision. What changes in
DM-3 and DM-4 is only whose firewall the traffic passes through.
Pensieve connects to a large number of systems a hospital already deals with: the national
digital health infrastructure, the claims exchange, payment providers, messaging providers, insurers and
third-party administrators, laboratory analysers, imaging archives, accounting packages, biometric devices
and government reporting portals.
For each of them there are five questions, and a hospital deserves the answers in writing before it signs:
Pensieve do technically?Pensieve deliberately not do?This document answers all five, for every integration class, and then sets out the responsibility matrix for the two that most often cause a go-live to slip: ABDM and NHCX.
DIS-GL-026: ABDM / NHCX Responsibility Matrix (RACI)
Pensieveacts as the hospital, on the hospital's own authority, using the hospital's own credentials.Edsol Edtech Pvt. Ltd.is never the regulated participant, never the registered entity, never the merchant, never the sender of record and never the counterparty to the external system.
Pensieve Labs builds and operates the connection. The hospital owns the relationship at the other end
of it.
Four reasons, in order of how much they matter to the hospital.
1. The registrations belong to the hospital by design. A Health Facility Registry identifier identifies a facility. A Healthcare Professionals Registry identifier identifies a clinician. An NHCX participant code identifies a claims participant. A payment merchant identifier identifies a merchant. In every case the regulator, the exchange or the network intends to know who the hospital is, not who its software vendor is. Putting the vendor in the middle of that relationship is an architectural error disguised as a convenience.
2. It keeps the hospital free to change software. A hospital whose ABDM credentials, merchant identifier
and insurer relationships are held in its vendor's name is a hospital that cannot leave. Pensieve Labs
regards vendor lock-in through credential custody as a form of hostage-taking, and does not practise it.
The credentials are issued to the hospital and remain the hospital's when the relationship ends.
3. It keeps liability where the law puts it. The hospital is the Data Fiduciary. The hospital is the health facility. The hospital is the claims participant. A vendor asserting those roles takes on regulatory exposure it cannot discharge and confuses the hospital's own compliance position.
4. It removes a certification dependency from the deal clock. Because Pensieve operates on
the hospital's credentials, a hospital does not have to wait for Pensieve Labs to complete a national
certification programme before it can go live.
Edsol Edtech Pvt. Ltd. does not hold ABDM M1/M2/M3 milestone certification and is not an ABDM-certified
hospital management system.
If your state health department, an incentive scheme, a payer, or an accreditation criterion requires that
the software itself hold ABDM milestone certification, Pensieve does not satisfy that
requirement. Nothing in this document changes that, and Pensieve Labs will not imply otherwise.
Check this at qualification. Section 3.5 tells you exactly what to check and who to ask. It takes one phone call and it can save you two months.
flowchart LR
subgraph HOSP["The hospital: registered participant, credential holder"]
HFR["HFR facility ID"]
HPR["HPR clinician IDs"]
NHCXID["NHCX participant code"]
MID["Payment merchant ID"]
SENDER["SMS / WhatsApp sender ID"]
TPA["Insurer and TPA relationships"]
end
subgraph PENS["Pensieve Labs: builds and operates the connection"]
VAULT[["Per-tenant credential vault<br/>encrypted, write-only"]]
CONN["Integration services<br/>protocol, mapping, retry, logging"]
end
subgraph EXT["External systems"]
A["ABDM Gateway / HIE-CM"]
N["NHCX"]
P["Payment networks"]
M["Messaging providers"]
I["Insurers / TPAs"]
L["Analysers, PACS, devices"]
G["Government portals"]
end
HOSP -->|supplies credentials| VAULT
VAULT --> CONN
CONN -->|calls as the hospital| A
CONN -->|calls as the hospital| N
CONN -->|calls as the hospital| P
CONN -->|calls as the hospital| M
CONN -->|calls as the hospital| I
CONN --> L
CONN -->|prepares submissions| G
Text description. The hospital holds every registration and credential: its facility registry identifier,
its clinicians' professional registry identifiers, its claims-exchange participant code, its payment
merchant identifier, its messaging sender identity and its insurer relationships. It supplies those
credentials to Pensieve's per-tenant encrypted vault. Pensieve's integration
services use them to call the external systems as the hospital. For government portals that have no
machine interface, Pensieve prepares the submission and the hospital files it.
The mechanics are set out in full in the BYOK/BYOC Credential Handling Disclosure (DIS-GL-025). The
security-relevant summary:
| Property | Position |
|---|---|
| Issued to | The hospital, by the external system's operator. Never to Edsol Edtech Pvt. Ltd. |
| Supplied how | Through a secure entry path in the Platform, by an authorised hospital user. Not by e-mail, not over a phone call, not in a spreadsheet |
| Stored how | In a managed secret store, encrypted under the tenant's own key (WPR-GL-001 Section 5.3) |
| Visible to whom | Nobody. Once supplied, a credential is never rendered back to any screen, report, export, log or support view. It is write-only from every direction |
| Used by what | Only the specific integration service that needs it, only for the tenant that supplied it |
| Logged how | Every use is logged: which system, when, what outcome. The credential value is never logged |
| Rotated by whom | The hospital, at any time. Pensieve Labs will prompt for rotation on a schedule the hospital sets |
| Revoked by whom | The hospital, at the source system, without Pensieve Labs's cooperation. Because they are the hospital's credentials, the hospital can kill them unilaterally at any moment |
| On offboarding | Deleted with the rest of the tenant's data and covered by the Certificate of Deletion (DIS-GL-023) |
The property that matters most. A hospital can revoke every credential Pensieve holds
without asking Pensieve Labs, without waiting for a support ticket, and without a contractual process
simply by going to each external system and revoking there. That is the strongest possible control a customer
can hold over a vendor's access to its external relationships, and it exists because the credentials were
never Pensieve Labs's.
| Component | What it is | Whose it is |
|---|---|---|
| ABHA Number (14-digit) and ABHA Address | The patient's health identity and the handle used for consent and record routing | The patient's. Created by the patient, or by the hospital with the patient's consent |
| HFR: Health Facility Registry | The national directory of health facilities. Produces a facility identifier | The hospital's. Registration is free, online, and done by the hospital |
| HPR: Healthcare Professionals Registry | The national index of clinicians, linked to council registration. Produces a professional identifier | Each clinician's, individually. Not the hospital's and not the vendor's |
| HIE-CM: Health Information Exchange and Consent Manager | The consent broker: issues, holds and validates consent artefacts and routes record requests | The national infrastructure. The patient links an ABHA to a consent manager |
| ABDM Gateway | The routing and discovery layer between information providers, information users and the consent manager | The national infrastructure |
| HIP / HIU roles | Health Information Provider: the system that holds and shares records. Health Information User: the system that requests and consumes them | The hospital plays both roles, through its software |
Sources for the component model: 01-research/india/01-regulatory-landscape.md Section 3, which cites the National
Health Authority's implementer documentation.
| Question | Answer |
|---|---|
| Who is the registered health facility? | The hospital. It holds its own HFR facility identifier |
| Who holds the professional registrations? | Each clinician, individually, in the HPR |
| Who holds the ABDM client credentials used by the software? | The hospital. They are issued against the hospital's facility registration |
| Who is the regulated participant in the ABDM ecosystem? | The hospital |
Is Edsol Edtech Pvt. Ltd. an ABDM-certified system? |
No. It does not hold M1, M2 or M3 milestone certification and does not seek it |
Does Pensieve Labs represent otherwise anywhere? |
No. See WPR-GL-005 Section 7 for the permitted-language table |
Pensieve does technicallyUsing the hospital's own credentials, and subject to Section 3.5:
Pensieve treats it as one.Pensieve does not conflate
them. See WPR-GL-003.Pensieve does not doEdsol Edtech Pvt. Ltd.'s name.Pensieve implements them.Pensieve Labs's control and is excluded
from the service level commitments (SLA-GL-001).Do this before signing. It takes one call.
| # | Question | Ask whom | If the answer is "yes" |
|---|---|---|---|
| 1 | Does our state health department mandate ABDM integration for facilities of our type, and does the mandate require the software to be milestone-certified, or only the facility to be HFR-registered and integrated? | State health department / district nodal officer | If it requires certified software, Pensieve does not satisfy it. Raise it with Pensieve Labs immediately |
| 2 | Are we claiming, or intending to claim, an incentive that is conditional on record sharing through a certified system? | Hospital finance / the scheme's guidelines | Confirm the scheme's exact wording on the software's status |
| 3 | Does the accreditation standard we are pursuing require an ABDM-certified information system? | The accreditation body's current standard text | Confirm before committing to an assessment date |
| 4 | Does any payer or aggregator we work with require it? | The payer | Get it in writing |
Pensieve Labs asks these questions in the first qualification conversation. If the answer to any of
them makes certified-vendor status a hard requirement, Pensieve Labs will say plainly that
Pensieve does not meet it, rather than proceeding and hoping. That conversation is unpleasant on
day two and catastrophic on day sixty.
| # | Item | Owner | Needed by | If it is late |
|---|---|---|---|---|
| 1 | HFR facility registration and the resulting facility identifier | Hospital | Start on day 1, in parallel with contracting | Blocks every downstream ABDM step. It is free and online, and it is the single most common cause of ABDM slippage |
| 2 | Facility-manager account and authority to link the facility | Hospital | With item 1 | Blocks credential issue |
| 3 | ABDM client credentials issued against the facility | Hospital | Before integration testing | Blocks integration testing |
| 4 | HPR identifiers for participating clinicians | Each clinician | Before any ABDM-signed clinical document is issued | Documents can be produced but not shared under the clinician's national identity |
| 5 | The hospital's decisions: which record types to share, which departments participate, patient-facing notice wording | Hospital | Before configuration | Blocks configuration |
| 6 | Named hospital owner for the ABDM workstream | Hospital | Day 1 | Unowned workstreams are where schedules die |
The National Health Claims Exchange is a standardised digital gateway routing health insurance claims between providers, payers and beneficiaries, built by the National Health Authority in consultation with the insurance regulator, under the national digital health umbrella. It replaces a hospital's separate integrations with each insurer and third-party administrator portal with a single standards-based submission.
The commercial point for a 50 to 200-bed hospital is receivables, not compliance: insurance is a large
share of revenue and the claims cycle is where the money sits. Source:
01-research/india/01-regulatory-landscape.md Section 4.
| Question | Answer |
|---|---|
| Who is the participant? | The hospital, as a provider participant. It holds its own participant code |
| What is a prerequisite? | The hospital's HFR facility registration |
| Who holds the NHCX credentials used by the software? | The hospital |
Is Edsol Edtech Pvt. Ltd. an NHCX participant? |
No. Pensieve Labs does not onboard as a participant in its own name |
| Who is the counterparty to the insurer or third-party administrator? | The hospital. Pensieve Labs is not a party to any claim, any settlement or any dispute |
Pensieve does technicallyPensieve
refuses to send an incomplete packet and tells the user what is missing, at the point of care, rather than
generating a rejection three days later.Pensieve does not doEdsol Edtech Pvt. Ltd.'s name.Pensieve Labs has no
relationship with any insurer or third-party administrator and no ability to influence a decision.| # | Item | Owner | Needed by |
|---|---|---|---|
| 1 | HFR facility registration (prerequisite to participation) | Hospital | Day 1 |
| 2 | NHCX participant registration and participant code | Hospital | Before claims testing |
| 3 | Production credentials for the exchange | Hospital | Before go-live on claims |
| 4 | The hospital's tariff structures, package definitions and payer mappings | Hospital | Configuration phase |
| 5 | Named owner in the billing office | Hospital | Day 1 |
| 6 | Existing payer and third-party administrator relationships and any portal credentials still required | Hospital | Configuration phase |
NHCX does not block a go-live. A hospital can be fully live on Pensieve for registration,
clinical, pharmacy, billing, stores, with claims still being filed the way they are filed today, and switch
to the exchange afterwards. Pensieve Labs recommends exactly that: go live first, then move claims.
Sequencing NHCX into the initial cutover adds a dependency on a third party's onboarding queue to a date the
hospital has already announced to its staff.
DIS-GL-026: ABDM / NHCX Responsibility Matrix (RACI)This section is the artefact DIS-GL-026. It is published here rather than separately so that no
hospital reads the boundary without the matrix, or the matrix without the boundary.
Legend. R = Responsible, does the work; A = Accountable, owns the outcome and cannot delegate it and C = Consulted before it happens, I = Informed after it happens. Every row has exactly one A.
| # | Activity | Hospital | Clinician | Pensieve Labs |
Authority |
|---|---|---|---|---|---|
| 1 | Register the facility on the Health Facility Registry | A/R | I | C | I |
| 2 | Maintain facility details and keep the registration current | A/R | None | C | I |
| 3 | Obtain a Healthcare Professionals Registry identifier | C | A/R | C | I |
| 4 | Link the clinician's professional identifier to the hospital record in Pensieve |
R | C | A | None |
| 5 | Obtain ABDM client credentials against the facility registration | A/R | None | C | I |
| 6 | Supply those credentials to Pensieve's vault |
A/R | None | C | None |
| 7 | Store, protect, rotate on instruction, and delete credentials on offboarding | I | None | A/R | None |
| 8 | Revoke credentials at the source system | A/R | None | I | I |
| 9 | Create or capture a patient's ABHA with the patient's consent | A/R | C | R (mechanism) | None |
| 10 | Verify the patient's ABHA and link it to the hospital record | I | None | A/R | None |
| # | Activity | Hospital | Clinician | Pensieve Labs |
Patient |
|---|---|---|---|---|---|
| 11 | Decide which record types the hospital shares | A/R | C | C | I |
| 12 | Decide the patient-facing notice wording and display it | A/R | None | R (mechanism) | I |
| 13 | Grant, vary or withdraw consent | I | None | R (mechanism) | A/R |
| 14 | Validate the consent artefact on every request and refuse out-of-scope access | I | None | A/R | I |
| 15 | Convert the clinical record into the required standard resources | I | C | A/R | Not applicable |
| 16 | Ensure the clinical content of a shared record is accurate | C | A/R | None | I |
| 17 | Encrypt and transmit the record to the requesting party | I | None | A/R | I |
| 18 | Log every share with consent reference, information types and timestamp | I | None | A/R | None |
| 19 | Respond to a patient's query about what was shared | A/R | C | R (evidence) | None |
| 20 | Raise a consent request as an information user, and honour its expiry | C | R | A/R | I |
| # | Activity | Hospital | Pensieve Labs |
Payer |
|---|---|---|---|---|
| 21 | Register as a participant and obtain the participant code | A/R | C | I |
| 22 | Supply exchange credentials to the vault | A/R | C | None |
| 23 | Configure tariffs, packages and payer mappings | A/R | R | C |
| 24 | Assemble the pre-authorisation or claim packet | I | A/R | None |
| 25 | Validate completeness before transmission | I | A/R | None |
| 26 | Decide what is claimed, at what value, with what documentation | A/R | None | I |
| 27 | Transmit the packet on the hospital's credentials | I | A/R | I |
| 28 | Adjudicate the claim | I | None | A/R |
| 29 | Respond to a query or a rejection | A/R | R (mechanism) | C |
| 30 | Reconcile settlement against receivables | A/R | R | I |
| 31 | Escalate a payer dispute | A/R | I | C |
| # | Activity | Hospital | Pensieve Labs |
Authority |
|---|---|---|---|---|
| 32 | Hold ABDM milestone certification for the software | None | Not held. Not sought. See Section 3.2 | None |
| 33 | Determine whether a certified system is required in this state or scheme | A/R | C | I/C |
| 34 | Comply with the national health data policy as a participating facility | A/R | C | I |
| 35 | Maintain the security of the record system | C | A/R | None |
| 36 | Notify a security incident to the national computer emergency response team | A/R | R (content, ≤4 hours) | I |
| 37 | Notify a personal data breach to the data protection authority and to data principals | A/R | R (content and affected-principal list) | I |
| 38 | Retain processing logs for the statutory minimum, inside India | C | A/R in DM-1/DM-2/DM-3; hospital A/R in DM-4 |
I |
| 39 | Respond to an audit or inspection by the authority | A/R | R (evidence and support) | C |
If a hospital reads nothing else in this document, read these.
| Row | Why it slips | How to prevent it |
|---|---|---|
| 1: HFR registration | Assumed to be Pensieve Labs's job. It is not, it is free, and every downstream step waits for it |
Start it on day 1 of the sales cycle, in parallel with contracting. Name an owner |
| 3: HPR identifiers | Each clinician must do it personally; nobody can do it for them, and doctors are busy | Start it on day 1. Expect it to take weeks of chasing, not days |
| 21: NHCX participant registration | Depends on the HFR identifier existing first, and on a third party's onboarding queue | Sequence claims after go-live (Section 4.6) |
| 33: Is a certified system required? | Nobody asks until an assessor asks | Ask at qualification (Section 3.5). One phone call |
| 23: Tariffs, packages and payer mappings | Large, tedious, hospital-owned, and always underestimated | Issue the template in the Hospital Input Pack in week 1 and track ageing per line |
Covers online payment gateways, card terminals, unified payments interface collections, and any payment aggregator the hospital uses.
| Question | Answer |
|---|---|
| Who holds the credential? | The hospital. The merchant account, the merchant identifier, the API keys and the settlement bank account are the hospital's |
| Who is the regulated participant? | The hospital, as the merchant. The payment aggregator or gateway is separately regulated. Edsol Edtech Pvt. Ltd. is neither |
| Who receives the money? | The hospital, into the hospital's own settlement account. Money never passes through any Edsol Edtech Pvt. Ltd. account |
What Pensieve does technically. Initiates a payment request against the hospital's bill,
using the hospital's gateway credentials; renders the payment interface or generates the collection link or
code; receives the gateway's callback; reconciles the payment against the invoice, the patient and the
encounter; posts the receipt; handles refunds initiated by an authorised hospital user; and produces the
day-end collection and reconciliation reports the cashier and the accounts department need.
What Pensieve does not do.
Edsol Edtech Pvt. Ltd. is not a payment
intermediary and is not licensed as one.Pensieve stores only the non-sensitive references the gateway returns: a transaction
reference, the last four digits, the instrument type, the status.What the hospital must provide. An active merchant account with its chosen gateway; API credentials issued to the hospital; the settlement bank account details for reconciliation; the refund authorisation matrix; the receipt numbering series and the tax treatment; and a named owner in accounts.
Covers transactional messaging to patients and staff: appointment confirmations, admission and discharge notifications, report-ready alerts, payment receipts and reminders.
| Question | Answer |
|---|---|
| Who holds the credential? | The hospital. The messaging account, the sender identity, the registered templates and the business messaging account are the hospital's |
| Who is the regulated participant? | The hospital, as the registered sender or principal entity under the telecom regulator's commercial-communication framework, and as the business account holder with the messaging platform |
| Who is the sender of record? | The hospital. A patient sees the hospital's sender identity, not Pensieve Labs's |
What Pensieve does technically. Triggers a message on a clinical or administrative event;
populates the hospital's approved template with the correct values; calls the hospital's messaging provider
using the hospital's credentials; records delivery status; retries on transient failure; and suppresses
sending where the patient has opted out or where the hospital's configuration says not to send.
What Pensieve does not do.
Pensieve sends transactional messages
arising from a clinical or administrative event. A hospital that wants to run a marketing campaign must
do it elsewhere, on a consent basis it manages.Pensieve Labs's control.The confidentiality point a hospital should think about before configuring templates. A message
containing a diagnosis, a test result or a department name discloses health information to whoever is
holding the phone. Pensieve supports minimised templates: "your report is ready, please
collect" rather than the result itself, and Pensieve Labs recommends them. The choice is the
hospital's, and it is a Data Fiduciary decision.
What the hospital must provide. A messaging provider account with credentials issued to the hospital; registered sender identity and approved templates; the template content and language variants; the opt-out handling policy; and a named owner.
Covers direct integrations and portal-based working with insurers, third-party administrators and government-funded scheme portals, where these are used instead of, or alongside, the claims exchange.
| Question | Answer |
|---|---|
| Who holds the credential? | The hospital. Empanelment, portal logins, provider identifiers and scheme registrations are the hospital's |
| Who is the regulated participant? | The hospital, as the empanelled provider. The insurer or administrator is separately regulated |
| Who is the counterparty? | The hospital. Edsol Edtech Pvt. Ltd. is not a party to any policy, empanelment, claim or settlement |
What Pensieve does technically. Maintains payer masters, tariffs, package definitions and
exclusion rules; assembles the pre-authorisation and claim documentation set from the clinical and billing
record; validates completeness against the payer's requirements before submission; where the payer offers a
machine interface, transmits on the hospital's credentials; where the payer offers only a portal, produces
the complete submission pack for a hospital user to upload; tracks status, queries, approvals, rejections
and ageing; and reconciles settlements and short-payments against receivables.
What Pensieve does not do.
Pensieve prepares the pack and a
hospital user files it.What the hospital must provide. Its empanelment list and provider identifiers; portal credentials where integration is possible and permitted; agreed tariffs and package definitions per payer; the documentation checklist each payer requires; the authorisation matrix for who may submit and who may accept a short-payment; and a named owner in the billing office.
Covers bidirectional interfacing with laboratory instruments: haematology, biochemistry, immunoassay, coagulation, urine analysers and microbiology systems.
| Question | Answer |
|---|---|
| Who owns the device? | The hospital, or the hospital's reagent or instrument partner under a reagent-rental or placement arrangement |
| Who holds the vendor relationship and the annual maintenance contract? | The hospital |
| Who is responsible for the analytical result? | The hospital's laboratory, and its accountable pathologist. Not Pensieve Labs and not Pensieve |
What Pensieve does technically. Sends the work order to the instrument or to the middleware
(order-entry direction); receives results over the instrument's supported protocol, typically HL7 v2
messaging over a network connection, or ASTM over serial or network where the instrument is older; maps
instrument test codes to the hospital's test master and to standard terminology where the hospital has
adopted it; applies the hospital's configured reference ranges, delta checks and critical-value rules;
routes results to the technologist's validation queue; and publishes only after the hospital's authorised
person validates.
What Pensieve does not do.
Pensieve. See DIS-GL-028.The security limitation, stated rather than glossed. Many analysers and their middleware speak protocols
that predate modern transport security, and some cannot be configured for encrypted transport at all. Where
such a device is in scope, the connection is confined to the hospital's own network segment, is not exposed
beyond it, and the limitation is recorded in the deployment record. Pensieve Labs does not describe
such a link as encrypted. See WPR-GL-001 Section 17.6.
What the hospital must provide. The instrument list with make, model, protocol and interface
capability; instrument vendor engagement where an interface licence or a driver is required: many
instrument vendors charge for the interface, and this is a hospital cost, not a Pensieve Labs cost;
network connectivity and addressing to each instrument; the test master and reference ranges; the
validation and auto-release policy; and a named owner in the laboratory.
Covers radiology and other imaging modalities, the picture archiving and communication system, and the worklist that connects them.
| Question | Answer |
|---|---|
| Who owns the modality and the archive? | The hospital, or its imaging partner |
| Who holds the PACS vendor relationship? | The hospital |
| Who is responsible for the image and its interpretation? | The hospital's radiology service and its reporting radiologist |
What Pensieve does technically. Publishes the modality worklist so a technologist sees the
correct patient, order and accession number at the modality rather than typing it; receives and stores the
study reference; links the study to the patient record, the encounter, the order and the invoice; launches
the hospital's viewer in context so a clinician moves from the order to the images without re-searching; and
manages the reporting workflow: assignment, draft, verification, sign-off, addendum and distribution.
What Pensieve does not do.
Pensieve does not render images for diagnostic
interpretation and must not be used for it. Diagnostic reading happens in the hospital's own validated
viewer on the hospital's own display.DIS-GL-028.What the hospital must provide. The modality and archive inventory with connection details; the archive vendor's cooperation and any interface licence it requires; agreed application entity titles, ports and network paths; storage capacity and retention policy for images, which remain in the hospital's archive; the reporting workflow definition and the sign-off authority; and a named owner in radiology.
Covers the hospital's statutory books, whether kept in a desktop accounting package, an enterprise finance system or a chartered accountant's own system.
| Question | Answer |
|---|---|
| Who owns the books of account? | The hospital |
| Who is responsible for statutory filings? | The hospital and its chartered accountant. Pensieve Labs is not the hospital's accountant, auditor or tax agent |
| Who holds the accounting system licence and credentials? | The hospital |
What Pensieve does technically. Maintains the operational financial record: billing,
receipts, refunds, credit notes, purchases, goods receipt, supplier invoices, payables ageing, receivables
ageing, stock valuation and consumption; produces posting-ready exports mapped to the hospital's chart of
accounts; and, where the hospital's accounting system exposes a supported interface and the hospital
supplies credentials, posts entries directly and reconciles what was posted against what was intended.
What Pensieve does not do.
Pensieve
applies the treatment the hospital configures, on the hospital's accountant's advice.What the hospital must provide. The chart of accounts and the mapping to Pensieve's
transaction types; the accounting system's version and interface capability; credentials where direct
posting is used; the tax configuration confirmed by the hospital's accountant; the financial year, document
numbering series and the period-close calendar; and a named owner in accounts.
Covers fingerprint, facial-recognition and card-based attendance terminals, and access-control devices where the hospital wants attendance and duty rosters connected.
| Question | Answer |
|---|---|
| Who owns the device? | The hospital |
| Who is the Data Fiduciary for employee biometric data? | The hospital. It decides whether to collect biometrics at all, on what basis, with what notice |
| Where does the biometric template live? | On the device, or in the device vendor's own controller. See below |
What Pensieve does technically. Reads attendance events, employee identifier, timestamp,
direction, device, from the device or its controller; maps them to the hospital's employee master; applies
the hospital's shift, roster, grace, overtime and leave rules; produces attendance registers, duty rosters,
exception reports and payroll inputs; and reconciles attendance against rostered clinical cover.
What Pensieve does not do.
Pensieve consumes the
attendance event, not the biometric. The template stays where the device vendor keeps it.Pensieve may consume its events; it does not grant or deny physical access.What the hospital must provide. The device inventory with make, model and interface; device credentials or controller access; the employee master with device identifiers mapped; the shift, roster and overtime policy; its own lawful basis and notice for biometric processing; and a named owner in human resources.
Covers statutory and public-health reporting: notifiable disease surveillance, birth and death reporting, district and state health returns, government-funded scheme portals, and employment-related statutory returns.
| Question | Answer |
|---|---|
| Who is the reporting entity? | The hospital. Every statutory return is filed by the hospital in its own name |
| Who holds the portal credentials? | The hospital |
| Who is liable for a late or incorrect return? | The hospital |
What Pensieve does technically. Captures the underlying data as a by-product of ordinary
clinical and administrative work, so that a notifiable diagnosis, a birth, a death, an adverse drug
reaction or an infection-surveillance event is recorded when it happens rather than reconstructed at
month-end; maintains the statutory registers a hospital is required to keep; generates the return in the
required format and to the required schedule; flags a due or overdue return to a named hospital owner; and,
where a portal offers a supported machine interface and the hospital supplies credentials, submits on the
hospital's behalf and records the acknowledgement.
What Pensieve does not do.
Edsol Edtech Pvt. Ltd.'s name, and is never the reporting entity.Edsol Edtech Pvt. Ltd.'s name.Pensieve applies the list the hospital configures and flags when the configuration was last
reviewed. Keeping it current is the hospital's obligation.Pensieve Labs treats a format change as a
defect and fixes it under the support process, but cannot pre-empt it.What the hospital must provide. The applicable return list for its state, district and facility type; portal registrations and credentials; the state notifiable-disease list and a review cadence; the format specifications for local returns; the named accountable person for each return; and confirmation of the filing calendar.
Across every integration class in this document, without exception:
Edsol Edtech Pvt. Ltd. is never the regulated participant, the registered entity, the empanelled
provider, the merchant, the sender of record, the reporting entity or the licence holder.Edsol Edtech Pvt. Ltd. never holds a credential in its own name on a hospital's behalf. Every
credential is issued to the hospital and is revocable by the hospital, unilaterally, at the source.Edsol Edtech Pvt. Ltd. never handles the hospital's money. Funds move between the hospital, its
payers and its patients through the hospital's own accounts.Edsol Edtech Pvt. Ltd. never makes a clinical decision. Pensieve does not diagnose,
triage, score, calculate a patient-specific dose or recommend treatment, in any integration.
DIS-GL-028 is the binding statement.Edsol Edtech Pvt. Ltd. never warrants a third party's system. Availability, latency, format
stability, adjudication outcomes and regulatory behaviour of external systems are outside
Pensieve Labs's control and are excluded from the service level commitments in SLA-GL-001.Edsol Edtech Pvt. Ltd. never uses a hospital's credential for any purpose other than the hospital's
own integration, and never for another tenant.Edsol Edtech Pvt. Ltd. never retains a hospital's credential after offboarding. Deletion is covered
by the Certificate of Deletion (DIS-GL-023).This is the consolidated list. It is issued as part of the Hospital Input Pack at Stage 2, with per-item ageing, because hospital-side inputs are the dominant schedule risk in every deployment.
| # | Item | Integration | Needed by | Consequence if late |
|---|---|---|---|---|
| 1 | HFR facility registration and identifier | ABDM, NHCX | Day 1 | Blocks all ABDM and all claims-exchange work. Free and online |
| 2 | Named owner per integration workstream | All | Day 1 | Unowned workstreams slip silently |
| 3 | ABDM client credentials | ABDM | Before integration testing | Blocks ABDM testing |
| 4 | HPR identifiers for participating clinicians | ABDM | Before ABDM-signed documents | Documents cannot carry the clinician's national identity |
| 5 | NHCX participant code and production credentials | NHCX | Before claims go-live (after cutover, Section 4.6) | Delays claims only, not go-live |
| 6 | Payment gateway merchant account and API credentials | Payments | Before billing go-live | Cash collection falls back to manual |
| 7 | Messaging provider account, sender identity, approved templates | Messaging | Before go-live | Patient notifications are unavailable at cutover |
| 8 | Payer empanelment list, tariffs, package definitions, portal credentials | Insurers, NHCX | Configuration phase | The largest single hospital-side data task. Start in week 1 |
| 9 | Instrument list with protocol and interface capability; instrument vendor engagement and any interface licence | Laboratory | Before laboratory go-live | Manual result entry at cutover |
| 10 | Modality and archive inventory, application entity titles, ports, archive vendor cooperation | Imaging | Before radiology go-live | Worklist and study linkage unavailable |
| 11 | Chart of accounts and mapping; tax configuration confirmed by the hospital's accountant | Accounting | Before financial go-live | Exports cannot be posted |
| 12 | Attendance device inventory and controller access; employee master | Attendance | Before payroll cycle | Manual attendance for one cycle |
| 13 | Statutory return list, portal registrations, state notifiable-disease list | Reporting | Before go-live | Returns fall back to manual |
| 14 | Decisions: record types shared, notice wording, refund policy, validation and auto-release policy, template content | All | Configuration phase | Configuration cannot be completed |
How Pensieve Labs handles this list. It is issued once, as a single pack, at Stage 2, not dribbled
out over six weeks. Every line has an owner, a due date and an ageing counter. Every line that
Pensieve Labs can pre-fill from information already supplied is pre-filled. The purpose is to make the
hospital's own critical path visible to the hospital on day two rather than on day forty.
| Failure | Owner | Pensieve Labs's role |
|---|---|---|
Pensieve's integration service is failing |
Pensieve Labs |
Fix, under SLA-GL-001 severities |
| A credential has expired or been revoked | Hospital | Detect, alert the hospital, guide re-supply |
| The external system is down or degraded | External operator | Detect, alert, queue and retry where the protocol permits, report status |
| The external system changed its format or specification | External operator | Treat as a defect, fix under the support process. Cannot be pre-empted |
| A payer rejected a claim on content | Hospital | Surface the reason code, support the rework |
| An instrument or archive is failing | Hospital and its device vendor | Assist diagnosis at the interface boundary |
| A registration was never obtained | Hospital | Flag it, escalate it, and refuse to describe the deployment as complete until it exists |
Where an external system is unavailable, Pensieve queues and retries in accordance with the
protocol, and surfaces the backlog rather than hiding it. Where a protocol does not permit safe retry,
because a duplicate submission would create a duplicate claim, a duplicate payment or a duplicate record,
Pensieve stops and asks a human rather than retrying blind. A hospital should expect an
integration failure to appear as a visible queue with an owner, not as a silence.
Integration failures follow the severity model and escalation path in SLA-GL-001. An integration failure
that prevents patient care (a laboratory interface down during a working shift, a worklist not reaching a
modality) is a high-severity incident regardless of whose system caused it, and Pensieve Labs engages
on that basis while the underlying ownership is established.
17.1 Edsol Edtech Pvt. Ltd. holds no ABDM milestone certification and no NHCX participant status.
Where a state, scheme, payer or accreditation criterion requires the software itself to be certified,
Pensieve does not satisfy it. Section 3.5 tells you how to check in one call.
17.2 Not every payer, instrument, archive or portal has a machine interface. Where one does not,
Pensieve prepares the submission and a human files it. Pensieve Labs will say which is the
case for a hospital's actual list during the technical review, rather than describing a general capability.
17.3 Some instrument vendors charge for the interface. Interface licences, drivers and middleware
licences demanded by an instrument or archive vendor are a hospital cost. Pensieve Labs will identify
them during the technical review; it cannot waive another vendor's commercial terms.
17.4 Some legacy devices cannot support modern transport security. See Section 9. The limitation is recorded, the link is confined to the hospital's network segment, and it is not described as encrypted.
17.5 Government portal formats change without notice. Pensieve Labs fixes format breaks as
defects. It cannot pre-empt them, and a return may need manual filing for one cycle.
17.6 The availability of every external system is outside Pensieve Labs's control, and is excluded
from the availability commitments in SLA-GL-001.
17.7 In DM-4, outbound connectivity is the hospital's. An integration cannot function through a
firewall Pensieve Labs cannot see, on an internet link Pensieve Labs does not control. DM-4
hospitals must plan outbound connectivity and its resilience as part of the deployment.
17.8 The integration list is not exhaustive. A hospital with an integration not listed here should
raise it at qualification. Pensieve Labs will say whether it is supported, whether it can be built, and
what it would cost, before signature, not after.
| Topic | Document |
|---|---|
| Credential custody, encryption, rotation, revocation and offboarding | DIS-GL-025 BYOK/BYOC Credential Handling Disclosure |
| Security controls, per deployment model | WPR-GL-001 Pensieve Security Whitepaper |
| Deployment models | WPR-GL-004 Deployment Models Explained |
What Pensieve Labs has, is getting, and does not have |
WPR-GL-005 Trust & Assurance Overview |
Why Pensieve is not a medical device |
DIS-GL-028 Clinical Safety Boundary Statement |
| Machine learning features and their boundaries | DIS-GL-027 AI/ML Feature Disclosure |
| Standards supported | DIS-GL-029 Interoperability & Standards Disclosure |
| Audit logging of integration activity | DIS-GL-013 Audit Logging & Traceability Disclosure |
| Breach notification content and timing | DIS-GL-016 Incident Response & Breach Notification Commitment |
| Deletion of credentials and data on exit | DIS-GL-023 Data Deletion & Return Disclosure |
| Severities, response times and exclusions | SLA-GL-001 Service Level Agreement |
| Processing terms | DPA-GL-001 Data Processing Agreement |
| Privacy and consent architecture | WPR-GL-003 Data Protection & Privacy Whitepaper |
| Version | Date | Author | Summary |
|---|---|---|---|
| 1.0.0 | 31 July 2026 |
Pensieve Labs Solutions |
First published edition. States the bring-your-own-credential boundary for ten integration classes; incorporates DIS-GL-026 (ABDM/NHCX RACI) at Section 5; publishes the qualification check for certified-system requirements and the consolidated hospital input list. |
Document control. DIS-GL-024 v1.0.0, Last Modified On 31 July 2026,
Review due 31 January 2027 | Tier: Public | Applies to DM-1, DM-2, DM-3, DM-4.
Incorporates DIS-GL-026.