Digital health compliance for CPTS
A CPTS coordinates independent health professionals around territorial missions: care pathways, prevention, unscheduled care. That coordination relies on information exchanges — directories, messaging, shared digital tools — which must be framed under the GDPR and professional secrecy.
What the regulations require of you
Each obligation is cited with its legal reference — so you know exactly where it comes from and what it demands of your organization.
Keep a record of processing activities
The CPTS documents its own processing: care-pathway coordination, directories, unscheduled care, territorial projects. This record is its own — it is not merged with its members'.
Inform patients and professionals
Every collection — territorial platform, directory, care pathway — must be explained to the people concerned: purposes, recipients, retention periods, rights.
Frame every shared tool by contract
Messaging, schedules, coordination platforms: each vendor is a processor and must be bound by a compliant contract with documented instructions.
Use HDS-certified hosting
Health data hosted on behalf of the CPTS must be hosted by a certified health-data host (HDS).
Qualify the DPO appointment obligation
Appointment becomes mandatory once the CPTS monitors health data on a large scale — which is assessed against the missions actually equipped with digital tools.
What is at stake for your organization
- Qualify the CPTS’s processing activities and responsibilities (data controller, joint controllership with its members).
- Frame the shared tools: secure health messaging, schedules, coordination platforms.
- Structure a record of processing activities suited to the CPTS’s core missions.
- Inform patients and handle their rights in a multi-professional context.
- Secure exchanges with territorial partners (facilities, the ARS, the health insurance fund).
What triggers the need
- Rolling out a new coordination tool or a territorial platform
- A request from the regional health agency (ARS) or a funder about data governance
- New members joining and the sharing of directories or schedules
- A first incident: a misdirected message, lost equipment, uncontrolled access
Sound familiar? Now is the right time to get the subject under control — before it takes control on its own.
The most common mistake
Assuming compliance is each member professional’s own business. The CPTS itself operates processing activities — coordination, directories, territorial projects — and carries responsibilities of its own that no member covers on its behalf.
What we put in place
- A compliance diagnostic scaled to your CPTS’s size and missions
- Record of processing activities and compliance documentation
- Framing of the digital coordination tools
- Awareness sessions for member professionals
- Outsourced DPO role, designated with the CNIL, where appointment is required or desired
Expertise backed by the NELSE technology
CPTS: our support relies on the tools developed by NELSE: each processing activity is qualified by written, sourced legal rules, the register stays up to date version after version, and the files handed over can be verified by a third party. The DPO assesses, advises and documents their opinions; your organisation keeps its decisions.
In practice, for you: the care-pathway coordination tool is described by facts (health data, multiple professionals, hosting processor): the regime follows with its grounds, and if a new vendor arrives, the record goes back to validation instead of staying true on paper.
Discover our softwareYour questions
Must a CPTS appoint a DPO?
Not systematically: the obligation depends on the processing actually carried out, in particular large-scale monitoring of health data. In practice, as soon as a CPTS equips care-pathway coordination with digital tools, appointing a DPO is strongly recommended — and often necessary. We analyze your situation during a free first call.
Who is responsible for the data exchanged between members?
It all depends on the tool and the purpose: the CPTS may be a data controller, a joint controller with its members, or a mere facilitator. This qualification determines everyone’s obligations; it is one of the first points we clarify.
Which coordination tools can we use?
Suitable tools exist (secure health messaging systems, regional platforms). The key is to verify HDS hosting where required, access rights and patient information. We audit your tools and secure how they are used.
Let’s secure the compliance of your organization
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