SaMD Cybersecurity and GDPR

Security = Safety

Under EU MDR, cybersecurity is a General Safety and Performance Requirement. Failure to secure software is a patient safety risk.

Technical Steps:

  • Secure architecture and testing (MDCG 2019-16)
  • Access control, encryption, logging
  • Vulnerability management and patches

GDPR Considerations:

  • Health data = special category
  • Explicit consent and purpose limitation
  • DPIA (Data Protection Impact Assessment) required if high-risk AI involved

This post is part of SaMD Europe Launch Guide.

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