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Pensieve Labs
The operating system for hospitals
WPR-GL-005
v1.0.0 | 31 July 2026
WPR-GL-005 v1.0.0, Last Modified On 31 July 2026, Tier: Public
This is the register. Where any other
Pensieve Labsdocument describes what assurance exists, this document is authoritative and more current. It is reviewed quarterly and re-dated in public when a target moves.
You are considering running your hospital's entire operation on software from a company you had not heard of last month. The reasonable question is: on what basis?
This document answers it in three columns.
| Column | Question it answers |
|---|---|
| Section 4: Held today | What can you check, right now, before you sign anything? |
| Section 5: In progress | What is coming, by when, and who is accountable for it? |
| Section 6: Not held | What does Edsol Edtech Pvt. Ltd. not have, including the things it has decided never to pursue? |
Edsol Edtech Pvt. Ltd. holds no security certifications. No ISO/IEC 27001. No SOC 2. No HITRUST. No
ABDM milestone certification. That sentence appears in the first screen of this document rather than in a
footnote, because a hospital that finds it in a footnote will reasonably wonder what else is in a footnote.
The rest of this document explains what exists instead, why it is worth something, and exactly what you should do with it during your evaluation.
Pensieve Labs will and will not say1.1 Edsol Edtech Pvt. Ltd. holds zero certifications and says so first. Not as a disclosure obligation
but as a positioning decision. An unknown vendor asking to run a whole hospital cannot survive a single
discovered overstatement, so Pensieve Labs does not make any.
1.2 What exists instead is a published evidence surface, not a promise. Every security control
Pensieve Labs operates is described specifically enough to be tested: named algorithms, named
retention periods, named notification windows, named responsibilities per deployment model. That is the
Security Whitepaper (WPR-GL-001), and it is public, versioned and dated.
1.3 Several items on that surface are independently checkable without Pensieve Labs's
cooperation. Anyone can score Pensieve Labs's transport security with a public scanner. Anyone can
send a vulnerability report and time the response against the published commitment. Anyone can verify that
every entity in the Subprocessor Register is a real company doing what is claimed. A hospital can ask for a
data export during evaluation and watch it happen. None of those tests requires trusting anybody.
1.4 The commitments are contractual, not aspirational. The four-hour breach notification, the export
obligation, the deletion certificate and the security schedule are in DPA-GL-001 and MSA-IN-001, which
Pensieve Labs publishes before you ask for them. A published contract is a stronger artefact than an
unpublished certificate, because you can read it and your advocate can hold Pensieve Labs to it.
1.5 The certification programme is real, sequenced and dated (Section 5), and the dates are published so they can be missed in public. A target that slips is re-dated with a reason, not quietly deleted.
1.6 Two things Pensieve Labs has decided never to buy, because pretending they are on a roadmap
would be dishonest: HITRUST, which is a United States health-plan artefact with no demand in
Pensieve Labs's markets; and medical-device conformity (ISO 13485, IEC 62304), because
Pensieve is deliberately not a medical device and buying device credentials would assert
otherwise. Section 6.4.
1.7 The ABDM and NHCX boundary is deliberate and it has operational consequences.
Pensieve Labs is not an ABDM-certified system and does not onboard to NHCX in its own name. The
hospital is the registered participant and holds its own credentials. This is an architectural decision,
stated affirmatively, and it is the one item in this document that can affect a go-live, so it has its own
document: the Integration Boundary Statement (DIS-GL-024). Read it before signing.
1.8 The single most useful thing you can do with this page: take Section 8 into your meetings with every other
vendor you are evaluating. The questions there are the ones that separate a real security posture from a
certificate on a wall, and Pensieve Labs is content to be judged by the same standard.
Buyers are routinely shown four categorically different things and told they are all "certifications". They are not, and the difference decides how much weight each deserves.
| Class | What it actually is | Who signs it | Can a vendor issue it to itself? | Examples |
|---|---|---|---|---|
| CERT: accredited certification | An assessment against a normative standard, by a certification body that is itself accredited by a national accreditation body | The certification body | No | ISO/IEC 27001:2022, ISO 9001 |
| ATT: independent attestation | A licensed or empanelled practitioner gives an opinion on management's assertion. A report with an opinion, not a pass mark | A CPA firm, an empanelled auditor, a registered assessor | No | SOC 2 Type II, a CERT-In empanelled auditor's report, a penetration test attestation letter |
| SELF: structured self-declaration | A standardised format the vendor completes and publishes. Its credibility comes from the format and from being published openly, not from a third party | The vendor | Yes | CAIQ, a Statement of Applicability, a security whitepaper, a VPAT |
| REG: registration or empanelment | Admission to a register run by a government or an infrastructure operator, usually with a conformance test attached | The register operator | No, but often free | ABDM milestone certification, Udyam, GeM |
Two rules follow, and Pensieve Labs applies both to itself.
Rule 1: a SELF artefact must say it is self-assessed, in the artefact, not in a footnote. Every
Pensieve Labs self-declaration carries its class on its face. The moment a buyer discovers that a
"certification" page was self-written, every other claim on the page becomes suspect.
Rule 2: a certificate at the infrastructure layer is not a certificate at the application layer.
Pensieve runs on Google Cloud, which holds its own independent certifications and audit reports
and whose India-region services are empanelled by the Ministry of Electronics and Information Technology
following an independent STQC audit. Edsol Edtech Pvt. Ltd. is neither empanelled nor certified. Any
vendor, including Pensieve Labs, who compresses that into "we are MeitY empanelled" is
misrepresenting. WPR-GL-001 Section 16.4 carries the exact permitted sentence.
This section is the argument. It is offered without embellishment, and a reader who disagrees with it should say so during the evaluation rather than after.
ISO/IEC 27001 certifies that an information security management system exists, is risk-driven, is
documented and is operating. It does not certify the product, it does not certify the absence of
vulnerabilities, and it does not tell you what happens to your data at 3 a.m. on a Sunday. It is genuinely
valuable (Pensieve Labs is pursuing it, Section 5), but it is frequently asked for as a substitute for
understanding, and it does not perform that function.
Five of them, all in WPR-GL-001, all testable during an evaluation:
| Control | How you check it in the evaluation |
|---|---|
| Data stays in India, in a named region | Ask which region. It is on the Order Form as Deal data region and in DIS-GL-008 |
| Every record access is logged immutably for at least 365 days | Ask to see the audit trail in a demonstration tenant. Ask what happens if Pensieve Labs tries to delete a log |
Pensieve Labs cannot casually reach your data |
Ask for the access request process. Ask for the access record for a specific support intervention |
| You can leave with your data | Ask for an export, before signature |
| You will be told about a breach in time to make your own regulatory report | Read the four-hour commitment in DPA-GL-001. It is a contract term, not a statement of intent |
A vendor with a certificate and no answer to those five is a worse choice than a vendor with no certificate
and a good answer to all five. Pensieve Labs invites the comparison.
Pensieve Labs publishes, without an email gate and without an NDA: the security whitepaper, the
architecture diagrams, the subprocessor register, the standard Master Services Agreement, the Data
Processing Agreement, the Service Level Agreement, the deletion and exit commitments, the deployment model
comparison, the integration boundary statement, and this document.
Larger vendors gate several of those. They can afford the friction. Pensieve Labs cannot, and the
consequence is that a hospital can evaluate Pensieve Labs's legal and security position completely
before it speaks to a salesperson. That is a structural advantage for the hospital, and it is deliberate.
Pensieve Labs starts clean on the current standardThe ISO/IEC 27001:2013 edition reached the end of its transition period on 31 October 2025, and non-transitioned 2013-edition certificates were withdrawn. A vendor showing a 2013-edition certificate today is showing an expired one, and would be treated as a new client requiring a full initial audit (SGS, September 2025; A-LIGN: ISO 27001 transition).
Pensieve Labs holds nothing and says so. When it certifies, it will certify against the 2022 edition
with no transition debt. Ask every vendor in your evaluation for the edition year printed on their
certificate, and for the accreditation body of the certifying organisation. Both questions are free, and
both are more informative than the certificate itself.
Pensieve Labs is asking a hospital to place its entire operation, clinical, financial, pharmacy,
stores, HR, on software from a company with no track record. One discovered overstatement would end that
conversation permanently and would end most of the conversations after it. The incentive to be accurate is
therefore stronger than the incentive to look impressive. That is not a character claim; it is arithmetic,
and it is the reason Section 6 of this document exists at all.
Each entry: what it is, class, why it is credible, what you should do with it.
WPR-GL-001)Class: SELF. A public, versioned, dated description of how Pensieve is built, hosted,
operated and defended, with a per-deployment-model treatment throughout, a section stating that no
independent validation exists, and a section listing what is not implemented.
Why it is credible. It is specific enough to be wrong. It names algorithms, retention periods,
notification windows, severity-based remediation targets and the exact split of responsibility between
Pensieve Labs and the hospital for each of DM-1 to DM-4. A document written to be unfalsifiable
reads differently, and a reviewer can tell.
What to do with it. Give it to your IT head and ask him to find something in it he can disprove. Then read Section 17 (the limitations) and decide whether the gaps listed there are acceptable for your hospital. That is the whole evaluation, compressed.
DIS-GL-006)Class: SELF. One diagram set per deployment model, showing trust boundaries and every point at which patient data crosses one.
Why it is credible. It commits Pensieve Labs to an architecture that either matches the running
system or does not. A hospital's technical reviewer can compare the diagram against what he observes.
What to do with it. Take it into the technical review and ask where the diagram is wrong. Ask
specifically about the boundary between Pensieve and every external system you intend to use:
that boundary is DIS-GL-024 and it is the one that causes go-live surprises.
DIS-GL-009) and change log (DIS-GL-010)Class: SELF, but falsifiable. Every sub-processor named, with its legal entity, the service provided, the data categories processed, the processing location and the date added, plus a commitment to notify before adding a new one.
Why it is credible. Because you can check it. Every named entity either exists and does what is claimed or it does not. Very few artefacts a vendor can produce for free are this easy for a buyer to verify.
What to do with it. Check three entries at random. Then confirm which entries apply to the deployment
model you are choosing: in DM-3 and DM-4 the hosting sub-processor leaves the chain entirely, because
you own the infrastructure.
Class: SELF, but contractual, which is stronger. The Master Services Agreement, the Data Processing Agreement with its DPDP Rule 6 security schedule mapped clause by clause, the Service Level Agreement and the standard Order Form are published on the Trust Center.
Why it is credible. A published standard contract cannot be quietly weaker for the next hospital, and your advocate can review it before a single meeting. The four-hour breach notification commitment, the export obligation, the deletion certificate and the audit rights are terms, not marketing.
What to do with it. Have your advocate read DPA-GL-001 Section on breach notification and compare the
four-hour commitment against every other vendor's. Most say "promptly". Under CERT-In's six-hour reporting
window, "promptly" is not a number a hospital can plan around.
security.txtClass: SELF, but externally testable. Published scope, safe harbour for good-faith researchers, and
response commitments: acknowledge within 3 business days, triage within 10, status update at least every 30
until closure. Published at /.well-known/security.txt per RFC 9116.
Why it is credible. Anybody can test it. Send a report and time the response. A vendor that publishes response times and then misses them has created evidence against itself, which is why most do not publish them.
What to do with it. If your organisation has a security function, have it send a low-severity report during the evaluation and measure the acknowledgement time.
Class: independent, in the narrow sense that the scanner is not Pensieve Labs's. Public scanners
score Pensieve Labs's own endpoints on TLS configuration, cipher suites and security headers.
Why it is credible. It is the only item in this column that a third party generates and that anybody
can re-run at any moment, including after Pensieve Labs changes something.
What to do with it. Run the scan yourself against https://trust.pensievelabs.org before your first
meeting. A vendor whose own trust site scores poorly on transport security has told you something useful
about its engineering discipline, and it costs you thirty seconds to find out.
Class: ATT and CERT, but they are Google's, not Pensieve Labs's. The physical security,
environmental controls, hardware lifecycle and data-centre operations underlying DM-1, DM-2 and DM-3
are covered by Google Cloud's own independently audited controls, and Google Cloud's India-region services
are MeitY-empanelled following an STQC audit.
Why it is credible, and precisely how far it goes. It is credible for the infrastructure layer and
worthless for the application layer. Pensieve Labs reviews the provider's audit reports annually and
records the review (DIS-GL-021), and states the boundary in the exact words set out in WPR-GL-001
Section 16.4.
What to do with it. Do not accept it (from Pensieve Labs or anyone else) as an answer to a
question about application security. And note that it does not apply at all in DM-4, where the physical
layer is yours.
DIS-GL-019)Class: SELF, machine-checkable. CycloneDX and SPDX, produced per release.
Why it is credible. It is operational rather than decorative. When the next widely exploited library
vulnerability is announced, a hospital can determine in minutes whether Pensieve is affected.
What to do with it. Ask what the SBOM was used for the last time a major vulnerability was disclosed. The answer distinguishes a generated file from a working process.
Class: SELF. Three documents that state, in advance, what Pensieve does not do:
DIS-GL-024): where Pensieve Labs's responsibility begins and
ends for every class of external integration, with the ABDM/NHCX responsibility matrix (DIS-GL-026).DIS-GL-028): why Pensieve is not a medical device,
and what it will therefore never do.DIS-GL-027): where machine learning is used, where it is not, and the
human review step.Why they are credible. They constrain the product roadmap, publicly. A boundary a vendor publishes is a boundary it has to keep.
What to do with them. DIS-GL-024 is the one that can affect your go-live date. Read Section 3 of it before
you commit to any ABDM or NHCX obligation with a state authority, an insurer or an accreditation body.
Class: SELF, but dated in public. The Trust Center publishes the date of the most recent restore drill, the most recent incident-response exercise, the most recent penetration test and the current SBOM release.
Why it is credible. Because a stale date is visible. Pensieve Labs publishes the date rather than
the claim, and if the date is old, it is old in public. That is the intended pressure.
What to do with it. Look at the dates before you look at anything else. Four current dates on a trust page tell you more about a vendor's operating discipline than thirty undated PDFs.
Every item below has a named owner and a target date. Both resolve from the Assurance Roadmap and both are published. When a target moves, this document is re-dated with the reason in Section 11, and the old target remains visible in the change history.
The order is chosen for what it unlocks per rupee and per day, not for what looks most impressive.
flowchart LR
P0["Phase 0: free, days<br/>Publish the evidence surface"] --> P1["Phase 1: weeks<br/>Independent VAPT, CAIQ<br/>insurance, escrow"]
P1 --> P2["Phase 2: months<br/>SoA, international pen test<br/>market-specific declarations"]
P2 --> P3["Phase 3: year one<br/>ISO/IEC 27001:2022<br/>then SOC 2 I → II → 3"]
Text description. Phase 0 publishes the free evidence surface in days. Phase 1 adds, in weeks, an independent vulnerability assessment and penetration test, a published self-assessed CAIQ, insurance and source-code escrow. Phase 2 adds, over months, the ISO 27001 Statement of Applicability published without certification, an international penetration test attestation, and market-specific declarations. Phase 3, in the first year, delivers ISO/IEC 27001:2022 certification followed by SOC 2 Type I, Type II and a publishable SOC 3.
Why ISO 27001 before SOC 2. The management system produces the control environment, the evidence
repository and the policy set that a SOC 2 readiness phase would otherwise build from scratch. Running SOC 2
first wastes that overlap. It also happens that ISO is the credential Pensieve Labs's actual markets
ask for, and SOC 2 is the one asked for by markets Pensieve Labs reaches later.
| # | Item | Class | Owner | Target | What it unlocks |
|---|---|---|---|---|---|
| 1 | Independent VAPT by a CERT-In empanelled information security auditing organisation, with a Safe-to-Host certificate and a publishable attestation letter | ATT | Roadmap certin vapt owner |
Roadmap certin vapt target |
The most locally authoritative credential available in India, and the cheapest independent assurance Pensieve Labs can buy anywhere |
| 2 | Self-assessed CAIQ v4, published on the CSA STAR Registry at Level 1 | SELF, on a public third-party register | Roadmap caiq owner |
Roadmap caiq target |
Removes the security-questionnaire round trip. Checkable by anyone, in any country, with no NDA |
| 3 | ISO/IEC 27001:2022 Statement of Applicability and the ISMS policy set, published uncertified | SELF | Roadmap soa owner |
Roadmap soa target |
Forces a documented decision on each of the 93 Annex A controls. Pensieve Labs publishes it openly, which most certified vendors do not |
| 4 | Certificate of cyber liability and technology errors & omissions insurance | Third-party instrument | Roadmap insurance owner |
Roadmap insurance target |
Converts the finance director's risk argument into a number and a policy limit |
| 5 | Source-code escrow: master deposit with beneficiary accession by joinder | Third-party instrument | Roadmap escrow owner |
Roadmap escrow target |
Answers "what if you disappear" with a document instead of a discussion, and without a fresh tripartite negotiation per hospital |
| 6 | Documented BC/DR restore drill with measured RTO and RPO, published quarterly | SELF, measured | Roadmap bcdr drill owner |
Roadmap bcdr drill target |
A measured restore outperforms a continuity policy in every market |
| 7 | Incident-response tabletop exercise with clock performance against the CERT-In 6-hour and DPDP 72-hour windows | SELF, measured | Roadmap tabletop owner |
Roadmap tabletop target |
Demonstrates that the four-hour notification commitment is executable, not decorative |
| 8 | Independent penetration test by an internationally recognised firm, with a publishable attestation letter | ATT | Roadmap pentest owner |
Roadmap pentest target |
Required outside India, where a CERT-In report carries no recognition |
| 9 | ISO/IEC 27001:2022 certification, with ISO/IEC 27017:2015 and ISO/IEC 27018:2019 in the same scope | CERT | Roadmap iso27001 owner |
Roadmap iso27001 target |
Hospital chains and group procurement; the prerequisite for most secondary-market shortlists. 27018 is the only ISO credential that certifies the processor role, which is Pensieve Labs's role in all four models |
| 10 | SOC 2 Type I, then Type II, then a publishable SOC 3 | ATT | Roadmap soc2 owner |
Roadmap soc2 target |
Enterprise and internationally owned groups. SOC 3 is the only member of the family that can be published without an NDA |
| 11 | ISO/IEC 27701 privacy information management, as an extension audit | CERT | Roadmap iso27701 owner |
Roadmap iso27701 target |
GDPR-jurisdiction buyers |
Pensieve Labs commits to about this tablePensieve Labs will not withhold a security document because the certified version is
coming.Pensieve Labs will not describe an in-progress item as held. Item 9 is not "we are ISO 27001
aligned" until the SoA is published, and it is not "certified" until a certificate exists with an
accreditation mark on it. Section 7 sets out the exact language.This section is deliberately longer than the previous one.
Edsol Edtech Pvt. Ltd. does not hold| Not held | What that means for you | Is it planned? |
|---|---|---|
| ISO/IEC 27001:2022 | No accredited body has assessed Pensieve Labs's information security management system |
Yes: Section 5.2 item 9 |
| ISO/IEC 27017 / 27018 | No certified assessment of cloud-specific controls or of processor-side privacy controls | Yes, in the same scope as 27001 |
| ISO/IEC 27701 | No certified privacy information management system | Yes (Section 5.2 item 11) |
| SOC 2 Type I or Type II | No licensed practitioner has opined on control design or operating effectiveness | Yes (Section 5.2 item 10) |
| SOC 1, SOC 3 | SOC 1 is not planned; SOC 3 follows the Type II | SOC 3 yes; SOC 1 no |
| ISO 9001 | No certified quality management system. Relevant mainly for Indian public and trust-hospital tenders, where it can be an envelope-stage eligibility gate | Conditional: only if Pensieve Labs pursues that segment |
| An independent penetration test that has been completed and attested | No external offensive-security assessment has yet been published | Yes, Section 5.2 items 1 and 8 |
| A paid bug bounty programme | Vulnerability research is invited under the VDP, but not funded | No current plan |
| An independent internal audit function | No separate function audits the controls in WPR-GL-001 against a schedule |
Introduced with the ISMS work |
| A 24×7 staffed security operations centre | Monitoring is continuous and alerts route to an on-call engineer; there is no staffed watch floor | Not at current scale |
This is the most important entry in this document, because it is the only one that can affect a go-live date.
Edsol Edtech Pvt. Ltd. does not hold ABDM M1/M2/M3 milestone certification, is not an
ABDM-certified hospital management system, and does not onboard to the National Health Claims Exchange
as a participant in its own name. This is a decision, not a backlog item.
The architecture instead. The hospital is the registered health facility. The hospital holds its own
Health Facility Registry identifier; its clinicians hold their own Healthcare Professionals Registry
identifiers; the hospital holds its own NHCX participant credentials. Pensieve operates a
bring-your-own-credential model: the hospital supplies its credentials, Pensieve Labs stores them
encrypted in a per-tenant vault, and the Platform calls those systems as the hospital, on the hospital's
own authority. Pensieve Labs is therefore not the regulated participant and does not represent that
it is.
Why this is a defensible position and not a gap. The registrations in question are facility registrations and participant registrations. They belong to the hospital by design: a Health Facility Registry identifier identifies a facility, and an NHCX participant code identifies a claims participant. A software vendor holding them on a hospital's behalf inserts a dependency between the hospital and its own regulator. The hospital keeps its credentials, keeps its relationships, and can change software without re-registering.
Where this could hurt you, stated plainly. If your state, your accreditation programme or an incentive
scheme requires that your hospital's software itself holds ABDM milestone certification, Pensieve Labs
does not satisfy that requirement, and no amount of the above changes it. That is a real constraint and it
must be checked at qualification, not at cutover.
What to do about it. Read the Integration Boundary Statement (DIS-GL-024) in full, and the ABDM/NHCX
Responsibility Matrix (DIS-GL-026) within it. It states, per integration class, who holds the credential,
who is the regulated participant, what Pensieve does technically, what it does not do, and what
you must provide and by when. Pensieve Labs surfaces this in the first qualification conversation
rather than at go-live, and if a hospital tells Pensieve Labs that certified-vendor status is a hard
requirement, Pensieve Labs will say so and stop rather than discover it later.
| Market | Not held | Consequence |
|---|---|---|
| India | NABH Digital Health Standards certification for the hospital information system | Rising in importance. Pensieve Labs publishes a self-assessment against the standard rather than claiming certification |
| India | ISO 9001, DPIIT recognition, GeM registration | Public and trust-hospital tenders may be closed to Pensieve Labs at the eligibility stage until these exist |
| Australia | IRAP | Not pursued. IRAP is an Australian government credential; Pensieve Labs sells to private hospitals |
| Denmark | MedCom certification | Not held. It is an engineering programme rather than a paperwork exercise, and it is not on the near-term roadmap |
| Norway | Normen supplier conformance declaration | Not yet published. It is free and is on the roadmap |
| UAE | NABIDH technical certification, and in-country hosting | Not held, and the hosting requirement is not currently satisfied. Pensieve Labs will not represent that data can be hosted in the UAE until it can be |
DIS-GL-008 states the residency position per market, including where it is not met. Pensieve Labs
would rather decline a market than describe a capability it does not have.
Pensieve Labs has decided never to pursuePublishing this is unusual and it is deliberate. A roadmap that contains everything is a roadmap that contains nothing.
HITRUST, in any tier. It is a United States health-plan and health-system vendor artefact, driven by
US-specific contractual requirements. No Indian, Australian, Danish, Norwegian or Emirati hospital
procurement process asks for it. Pursuing it would consume more cash than Pensieve Labs's entire
certification programme and would unlock nothing. If a United States buyer ever appears, the decision will
be revisited on the record.
ISO 13485, IEC 62304 and medical-device conformity. Pensieve is deliberately outside the
software-as-a-medical-device boundary: it does not diagnose, triage, score clinical risk, calculate
patient-specific doses or recommend treatment. Buying device credentials would be an implicit assertion that
Pensieve is a device, which invites regulatory questions to which Pensieve Labs
currently has a clean answer. The Clinical Safety Boundary Statement (DIS-GL-028) is published instead,
and it constrains the product roadmap rather than merely describing it.
The corollary, stated because it is the honest one. This position permanently constrains what
Pensievecan become. If a hospital needs interaction-severity scoring, patient-specific dose calculation, imaging triage or an early-warning score,Pensievedoes not provide it and will not provide it without first undertaking the device-conformity route.Pensieve Labswould rather say that in a sales meeting than discover it in a regulator's letter.
Cyber Essentials and Cyber Essentials Plus. United Kingdom credentials; Pensieve Labs does not sell
in the United Kingdom.
A speculative SIG licence. The Shared Assessments questionnaire is licensed rather than free.
Pensieve Labs will answer one reactively from its CAIQ evidence base rather than licensing it against a
demand that has not materialised.
These are restated from WPR-GL-001 Section 17 because a hospital reading only this document should still see
them.
WPR-GL-001.Edsol Edtech Pvt. Ltd.'s size, the same small group builds and operates
the Platform. Compensating controls are mandatory peer review, second-person approval for production
access, and immutable audit logs the accessing engineer cannot alter.DM-1 and DM-2, Pensieve Labs can technically decrypt hospital data through an approved,
time-bound, logged path. There is no customer-held-key architecture in the hosted models. Hospitals
requiring a structural rather than procedural control should choose DM-3 or DM-4.DM-2 isolation is logical, not physical.DM-4, and no RTO or RPO commitment for infrastructure
Pensieve Labs does not control.Pensieve Labs does not publish a customer list, logos or reference letters, because it does not yet
have consented references to publish. It will not manufacture them, will not describe a pilot as a
deployment, and will not name a hospital without written consent.
What a buyer should do with that. Treat it as a real risk and price it. Ask to speak to the engineering
team rather than to a reference. Ask for a proof of concept against your own data. Ask for the first-customer
commercial terms. Being early should be worth something, and Pensieve Labs treats it as worth
something.
This table is binding on every Pensieve Labs document, proposal, questionnaire response, sales
conversation and web page. It is published so that a hospital can hold Pensieve Labs to it, and so that
a hospital can apply the same test to every other vendor in its evaluation.
Pensieve Labs will never say |
Pensieve Labs says instead |
|---|---|
| "We are ISO 27001 compliant" | "Pensieve Labs operates an information security management system aligned to ISO/IEC 27001:2022. Edsol Edtech Pvt. Ltd. is not certified. The Statement of Applicability is published." |
| "We are CERT-In certified" | "The Platform was audited by a CERT-In empanelled information security auditing organisation. The attestation letter and the Safe-to-Host certificate are published; the full report is available under NDA." |
| "We are MeitY empanelled" | "Pensieve runs on Google Cloud in the India regions, which are MeitY-empanelled following an STQC audit. Empanelment applies to the cloud infrastructure, not to the Pensieve application." |
| "We are HIPAA compliant" | HIPAA does not apply to Indian hospitals. Pensieve Labs's controls are documented against the DPDP Act 2023 and the DPDP Rules 2025, the law its buyers actually face. |
| "We are ABDM certified" | "Pensieve Labs is not ABDM-certified and does not seek milestone certification. The hospital is the registered facility and holds its own credentials; Pensieve integrates on the hospital's authority. See DIS-GL-024." |
| "We are GDPR compliant" | "Edsol Edtech Pvt. Ltd. acts as a processor. The Data Processing Agreement incorporates Article 28 terms; the subprocessor register and transfer mechanisms are published." |
| "SOC 2 certified" | SOC 2 produces a report, not a certificate. "Pensieve Labs has completed a SOC 2 Type I examination performed by a named CPA firm; the Type II window runs from ⟨date⟩ to ⟨date⟩." |
| "Bank-grade security" / "military-grade encryption" | The algorithm, the key length, the key management service and the rotation period, by name. WPR-GL-001 Section 5. |
| "Our platform is secure" | The controls that are implemented, and the ones that are not. WPR-GL-001 Section 17. |
| "99.99% uptime" as a bare figure | The availability commitment with its measurement method, its exclusions and the deployment models it applies to. SLA-GL-001. |
"Your data is fully isolated" (for DM-2) |
"DM-2 isolation is logical, in four layers, and it is not equivalent to DM-1. DIS-GL-032." |
If you ever receive a Pensieve Labs document, proposal or e-mail containing a sentence from the left
column, it is wrong. Send it to info@pensievelabs.org and it will be corrected and the
correction recorded.
Take these into every vendor meeting, including Pensieve Labs's. They are ordered by how quickly they
separate a real posture from a decorative one.
| # | Question | What a good answer looks like |
|---|---|---|
| 1 | What edition year is on your ISO certificate, and which body accredited the certifier? | "2022, accredited by ⟨national accreditation body⟩." A 2013 edition means the certificate is dead |
| 2 | Show me the audit record of the last time one of your engineers accessed my kind of data in production | An access request with a reason, an approver, a time bound and a log entry |
| 3 | How many hours after you become aware of a breach will you tell me, and is that number in the contract? | A number, in the contract. Anything short of six hours from your notice makes CERT-In's window unachievable |
| 4 | Where exactly are my logs stored, for how long, and can you delete them? | A named region inside India, at least 365 days, with retention lock so the vendor cannot shorten it |
| 5 | Export my data now, in front of me | It happens, or it does not |
| 6 | Who holds the encryption keys, and can I revoke your access without your cooperation? | Honest answer per deployment model. "You can" is only true if you own the account |
| 7 | Which of your certifications belong to your cloud provider rather than to you? | An accurate boundary. Most vendors blur this |
| 8 | What is on your product roadmap that would make you a medical device? | A boundary the vendor has written down, or an uncomfortable pause |
| 9 | Who holds the ABDM and NHCX credentials in your model, you or me? | Either answer can be right; not knowing is not |
| 10 | What is not implemented yet? | A list. A vendor with no answer to this question has not thought about it or is not telling you |
Pensieve Labs has published answers to all ten. Question 10 is WPR-GL-001 Section 17 and Section 6.5 of this
document.
| Mechanism | Detail |
|---|---|
| Review cadence | Quarterly, or immediately on any change of status. review_due_on is in this document's own metadata and drives an internal staleness alert |
| Published dates | Every item carries a date. A stale date is visible to the public rather than hidden |
| Slipped targets | Re-dated here with a reason, recorded in Section 11. Targets are not deleted |
| Correction channel | info@pensievelabs.org. Any reader who finds a statement in any Pensieve Labs document that is inaccurate can report it, and the correction is recorded |
| Precedence | Where this document and any other Pensieve Labs artefact disagree about what assurance exists, this document is correct |
| What is never done | An item is never moved from Column 3 to Column 1 until the underlying artefact exists and is published or produceable on request |
| Topic | Document |
|---|---|
How Pensieve is built, hosted and defended |
WPR-GL-001 Pensieve Security Whitepaper |
| The four deployment models | WPR-GL-004 Deployment Models Explained |
| Architecture in technical depth | WPR-GL-002 Architecture & Technical Overview |
| Privacy and DPDP | WPR-GL-003 Data Protection & Privacy Whitepaper |
| Sub-processors | DIS-GL-009, DIS-GL-010 |
| Data residency per market | DIS-GL-008 |
| Backups, RTO and RPO | DIS-GL-014 |
| Breach notification commitments | DIS-GL-016 |
| Dependencies and SBOM | DIS-GL-019 |
| Integration boundary, ABDM and NHCX | DIS-GL-024, DIS-GL-026 |
| Hospital-supplied credentials | DIS-GL-025 |
Why Pensieve is not a medical device |
DIS-GL-028 |
| Multi-tenancy | DIS-GL-032 |
| Contract stack | MSA-IN-001, DPA-GL-001, SLA-GL-001 |
| Exit and deletion | WPR-GL-400, DIS-GL-023 |
| Version | Date | Author | Summary |
|---|---|---|---|
| 1.0.0 | 31 July 2026 |
Pensieve Labs Security |
First published edition. States zero certifications held; publishes the assurance programme with owners and targets; publishes what Pensieve Labs has decided never to pursue; publishes the permitted-language table. |
Target changes are recorded in this table with the previous target, the new target and the reason. No target is removed.