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    Aarthi Raghavan, Asia’s Digital Health Innovations: The role of cross-border health data sharing

    Published On: 12 October 2023

    Asia House Fellow Aarthi Raghavan conducted an in-depth research and analysis on the impact of cross-border sharing of health data on health innovations in five major Asian economies of China, India, Indonesia, Malaysia and Singapore. In the process, Aarthi has also identified both the key barriers and opportunities in each country studied. 


    This research paper explores the current impact and future promise of cross-border sharing of health data on innovations across five Asian countries: China, India, Indonesia, Malaysia and Singapore.

    The overall findings are:

    • Sharing health data in Asia continues to be restricted by the lack of a common platform, and by differing national regulatory regimes, unequal digital infrastructures, and shortages of healthcare and IT staff.
    •  Governments are responding (to varying degrees) and healthcare startups are lining up to develop necessary innovation.
    • The main barriers remain concerns over sharing citizens’ data, worries about cyber threats, and cost.

    At the country level, the findings are:

    • China faces significant challenges to sharing health data because of its highly decentralised healthcare system, and the concern of both government and citizens about data security. Despite this, a less restrictive and more proactive regulatory approach has fuelled a market-based digital health innovation landscape. This has helped local startups and technology companies to scale up their innovation in the local market within shorter timelines. As a result, digital health startups in China have become increasingly attractive for global investors.
    • India’s healthcare systems, which are highly decentralised in terms of governance, have also created structural inefficiencies in sharing health data. The government is implementing the Ayushman Bharat Digital Mission to overcome these challenges and enable health data interoperability – essentially linking tech systems – across public and private healthcare systems, as well as in urban and rural areas. The country recently passed the Digital Personal Data Protection Act 2023, which is more open to cross-border sharing of data and places strict conditions on the protection of health data during such transfers.
    • Inefficiencies in health data collection and sharing have plagued digital health innovations in Indonesia. As such, the government is trying to combine existing health data systems onto a single platform called SATUSEHAT, and calling for startups to participate. In terms of cross-border sharing of health data, while the data protection law allows it, subsequent regulations for implementation are expected to become more restrictive due to strict government oversight.
    • Malaysia has a robust and centrally regulated healthcare system, but government efforts to build comprehensive electronic health records (EHR) have been largely unsuccessful so far. It is currently banking on the Malaysia Health Data Warehouse to overcome existing challenges by bringing more hospitals and clinics together to actively share health data. The government provides abundant funding and support for digital health startups and has recently identified five hospitals to collaborate with them. Malaysia does allow cross-border data sharing, but in limited situations based on strict compliance with personal data protection legislation.
    • Singapore, an early adopter of EHRs, has an advanced healthcare system, and the government actively encourages digital health startups and supports them with world-class facilities and funding. Health data sharing at the institutional levels and by means of active business-to-consumer (B2C) models has enabled unique innovations in healthcare. Yet data security remains a challenge. Hence, the government is planning to introduce enhanced regulations to protect personal data, prompting healthcare providers, technology companies and startups to be especially cautious and avoid cross-border sharing of health data as much as possible.

    Executive Summary

    Country-wide EHRs are a crucial element in better healthcare. While digital health startups and technology companies tend to remain focused on serving urban, tech-savvy populations, government-led initiatives to create national records generate true data value. This allows for startups and technology companies to glean the more detailed and specific data they need for the health issues their innovations are trying
    to address.

    The report identifies a quid pro quo for governments with national databases. In exchange for providing the conditions needed by startups – funding, regulatory sandboxes, etc. – governments can expect the digital health innovators themselves to contribute their own data to the national database, making it broader and more accurate. Additionally, the more digital health startups participate in the process, the more governments will be able to amend regulations in a way that enables them.

    For the startups themselves, a key benefit of participating in national electronic health databases is that they can more easily expand from business-to-business (B2B) to B2C activities, depending on the kind of solution they are offering.

    As things stand, higher regulatory restrictions tend to lead to digital health startups preferring a B2B over a B2C model. The latter requires use of personal data and attracts more regulation; the former tends to operate by partnering with experienced stakeholders who are already compliant with regulations, reducing the burden for startups.

    The paper notes, however, that national EHRs can enable more digital health startups to offer consumer-facing solutions. A less restrictive approach by governments to digital health startups can enable innovations to increase in size and depth. Conversely, an uncertain regulatory environment may push startups to adopt a cautious approach, limiting innovation and growth.

    When it comes to cross-border health data sharing, concerns about the misuse of data are the main barrier to digital health innovation. Stakeholders are especially worried about regulatory repercussions if health data is breached or misused in the process of crossborder sharing. For digital health startups that are still small, this is a huge impediment as they lack the bandwidth to comply with complex regulations.

    This all leads to a contradiction. Governments want to attract global innovations in local healthcare systems, but also want to restrict cross-border health data sharing because of privacy issues. They find this a viable model to encourage local innovation. But the governments that are able to innovate also want to share their innovations with other countries to exert their expertise regionally and globally.


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