Service · Software development

Custom NEN 7510 compliant software development.

Custom healthcare software that complies with NEN 7510, the Dutch standard for information security in healthcare. Audit logging, role management, encryption and data residency are built in from the first design, not bolted on afterwards.

NEN 7510-1/2/3Audit loggingEncryptionEU data residency

NEN 7510 is not an afterthought.

NEN 7510 is the Dutch standard for information security in the healthcare sector: a healthcare-specific supplement to ISO 27001, mandatory for any organisation processing personal health data. The standard consists of three parts: NEN 7510-1 describes the management system, NEN 7510-2 the concrete control measures, and NEN 7510-3 sets requirements for audit logging.

In practice, we often see software that is "made compliant later" retain structural shortcomings: audit logs the owner can switch off themselves, role models patched after the fact, or cloud choices that wouldn't pass a Schrems II assessment. We build the other way round: the compliance architecture first, then the features around it.

We work with healthcare organisations (hospitals, mental health and long-term care), GP cooperatives, dentists and physiotherapists going digital, pharmacists, EHR vendors, health insurers, healthcare IT suppliers and health-tech start-ups bringing their first medical product to market. For research institutions, including university medical centres, RIVM and ZonMW consortia, we build platforms with pseudonymisation, purpose limitation and strict sub-processor control. We don't build EHR replacements for ChipSoft, Epic, CGM, HiX or Topicus, but we do build the modules and portals that run alongside those systems and exchange data via HL7 FHIR or MedMij.

Three types of NEN 7510 projects.

The standard is the same, but the scope of software in healthcare varies greatly. In the first conversation we advise which approach suits your situation. A patient portal calls for something different than a telemedicine platform or a research environment with pseudonymisation.

Compact project · fixed sprint budget

Patient or client portal

A secure environment where patients can view record items, book appointments, complete questionnaires or communicate securely with their care provider. Log in with DigiD or MedMij, role-based access, an immutable audit trail and a patient-rights flow for access, correction and data portability.

DigiD / MedMijRole managementAudit logGDPR flow
Mid-sized project · fixed sprint budget

Care module or telemedicine platform

A dedicated healthcare module alongside the EHR: a referral integration, a telemedicine consultation, questionnaires with clinical scoring, or a module for specific conditions. Includes HL7 FHIR integrations, encryption at rest and in transit, sub-processor management and a DPIA process with your DPO or CISO.

HL7 FHIRDPIAEncryptionSub-processors
Larger project · fixed sprint budget

Research or AI platform with healthcare data

A research platform with pseudonymisation and purpose limitation, or an AI tool that falls under the MDR and the AI Act alongside NEN 7510. A mission-critical setup with IaC, security scans (Checkov, Trivy), an external pen test before go-live and a mapping document that demonstrably covers the standard for your organisation.

PseudonymisationMDR + AI ActIaC + scansPen test

What you get at the end.

A working platform plus the documentation you need to demonstrate NEN 7510 requirements, to your own quality function, an external auditor or the Dutch Data Protection Authority.

  • Production-ready softwareProduction and staging environments in an EU region, running in your cloud (GCP, AWS Frankfurt, Azure West Europe) or with us. No US-only services in the critical path.
  • NEN 7510 mapping documentFor each control measure from NEN 7510-2, records where and how it is implemented in the system. Directly usable as evidence for your certification.
  • Audit log compliant with NEN 7510-3Immutable logging of who accessed which record, when and from where. Stored in a separate domain that cannot be switched off by functional management, with configurable retention periods.
  • Codebase, IaC and runbooksFull source code, Terraform/Pulumi infrastructure-as-code, and runbooks for incident response, restore tests and the 72-hour Dutch Data Protection Authority breach notification flow.
  • Third-party pen test reportExternal security audit before go-live, with follow-up action points and a retest. We do not hand over until the findings have been resolved.
  • Training for your IT and compliance teamSessions for your functional management, DPO and CISO on architecture, use of the audit log and the DPIA approach for new features.
  • Maintenance contract (optional)Monitoring, backups, security patches, an annual pen test and ongoing development. Fixed monthly fee with SLAs per severity category.

When custom NEN 7510 software is the right choice.

Four patterns in which we support healthcare organisations. Standard EHR replacement is not among them. For ChipSoft, Epic, CGM or HiX, we build modules around the system, not alternatives to it.

Alongside the EHR

A module the EHR doesn't offer

The EHR handles the core, but for a referral portal, questionnaires with scoring or a patient journey app, you run into its limits. You want something that connects via HL7 FHIR but sits under your own brand and compliance.

Health-tech start-up

First healthcare product to market

You are building a digital therapeutic, a telemonitoring app or an AI diagnostic tool. NEN 7510 is unavoidable for sales to hospitals, and investors and buyers explicitly ask for it.

Research

Research platform with patient data

An academic medical centre, research institute or consortium that needs to analyse data from multiple care providers. Pseudonymisation, purpose limitation and watertight access control are not optional.

Cloud transition

Legacy application to the cloud

An existing healthcare application still runs on-premise or in a setup that no longer passes the standard assessment. You want to move to a modern EU cloud architecture without losing your compliance footing.

How a NEN 7510 project runs.

1

Introduction and scope

A conversation in which we understand the healthcare context: which data, which target group, which EHR, which partners. We identify early on whether, alongside NEN 7510, MDR, the AI Act or the WGBO also play a role.

2

Compliance blueprint and architecture review

Together with your DPO or CISO we map the architecture against NEN 7510-2 and NEN 7510-3. Data flows, sub-processors, encryption strategy, key management and the audit log design are settled before we write any code.

3

Build in sprints with security by default

Two-weekly sprints with working builds. Secure-by-default frameworks, automated security scans (Checkov, Trivy, dependency checks) in the pipeline, and a DPIA update for every feature that touches personal health data.

4

External pen test and NEN mapping

Before go-live we have an external security firm pen test the system. Findings go back into a sprint, followed by a retest. In parallel we finalise the NEN 7510 mapping document so your audit process starts with the evidence in place.

5

Rollout and ongoing management

Phased rollout, training for functional administrators and end users and, if you wish, ongoing management including an annual pen test, patch management and quarterly DPIA reviews for new features.

The technical controls we set up as standard.

NEN 7510-2 describes control measures at a high level. These are the concrete implementations we build into every healthcare application, regardless of scope. The tailoring lies in how they come together, not in whether they are there.

Access

Role-based, least privilege, MFA

A role model based on the principle of least privilege, MFA mandatory for all users with access to patient data, session management with automatic logout and device binding where needed. Login via DigiD, MedMij or the care organisation's identity provider.

Encryption

Data at rest and in transit

AES-256 or stronger for data at rest, TLS 1.2+ for data in transit, client-side encryption for the most sensitive fields, and a key management strategy in which keys are separated from the encrypted data, often with KMS or HSM integration.

Logging

Tamper-evident audit trail

An audit log compliant with NEN 7510-3: write-only storage, a separate domain, not switchable off by functional administrators, with configurable retention and alerting rules for suspicious patterns (bulk queries, access outside office hours, access to one's own record).

Patient rights

GDPR flows built in

Self-service or guided flows for access, correction, restriction, erasure and data portability. In a care context, erasure often means restricting access while retaining data for the statutory retention period, and we build that nuance in carefully.

Suppliers

Sub-processor management

An inventory of all cloud and SaaS providers in the chain, data processing agreements in order, a Schrems II assessment for each provider with US ownership, and periodic review of the sub-processor register.

Incident

72-hour Dutch DPA notification flow

Incident response runbook with escalation matrix, pre-drafted notification templates for the Dutch Data Protection Authority (Autoriteit Persoonsgegevens), and rehearsed restore procedures, so that you can act within the stipulated deadlines in practice.

Compliance overlays we often build in.

NEN 7510 rarely stands alone. Depending on what the software does, additional frameworks come into play. A telemonitoring app that raises alarms is a medical device (MDR). An AI tool that predicts risk falls under the AI Act. A platform that exchanges patient data must comply with MedMij, and interoperability almost always runs via HL7 FHIR, or for legacy integrations via HL7v3 or EDIFACT.

We map out these overlays before we begin, so that the design supports them rather than conflicts with them. An MDR classification of class IIa affects the development process (technical file, post-market surveillance), not just a box to tick. For enterprise healthcare contexts, we see this layering frequently in our enterprise software projects, and for research platforms in our broader healthcare software approach.

What we explicitly don't do: tick off NEN 7510 as a checklist and then resume feature work without any connection to it. The standard is an attitude, and we build that attitude structurally into the architecture, the development process and the team's governance.

Frequently asked questions.

What healthcare clients usually want to know before we begin.

What exactly is NEN 7510?
NEN 7510 is the Dutch standard for information security in healthcare and is mandatory for any organisation processing personal health data. The standard consists of three parts: NEN 7510-1 describes the management system (governance, responsibilities, risk approach), NEN 7510-2 provides concrete control measures (access, encryption, supplier management), and NEN 7510-3 sets specific requirements for logging access to patient data.
What is the difference between NEN 7510 and ISO 27001?
ISO 27001 is the international standard for information security across all sectors. NEN 7510 builds on it with healthcare-specific additions: stricter logging requirements, purpose limitation for health data, an explicit patient-rights flow and rules around sub-processors in healthcare. Anyone who complies with NEN 7510 effectively also meets the basis of ISO 27001, but not the reverse. We also help with ISO 27001-compliant software if that is the broader scope.
How do NEN 7510, GDPR and MDR relate to one another?
Three layered frameworks. The GDPR governs the processing of personal data and grants patients their rights. NEN 7510 translates information security into the healthcare context. The MDR applies as soon as software classifies, diagnoses or treats, at which point it is a medical device. For AI applications, the AI Act also comes into play, often in the high-risk category. We advise which frameworks apply and how they overlap. See also our page on GDPR-compliant platforms.
What does the audit logging requirement of NEN 7510-3 involve in practice?
NEN 7510-3 requires that every access to a patient record is recorded: who, what, when and from where. The logs must be tamper-proof, retained for a long period, and not switchable off by the functional administrator themselves, which separates the logging function from the user function. We implement audit logging as a first-class concept in the architecture (a separate storage domain, write-only, with separated keys), not as an afterthought bolted on with Sentry.
Can patient data be stored in the cloud with AWS, Azure or Google Cloud?
Yes, provided it is held in an EU region, with the appropriate data processing agreement, encryption keys under your control, and a Schrems II assessment of the risks arising from US ownership. By default we deploy to AWS Frankfurt, Azure West Europe or GCP europe-west4, with client-side encryption for the most sensitive data. For some healthcare organisations the Schrems II risk weighs heavily enough to choose a European cloud (such as Cleura or a Dutch private cloud), and we keep that option open.
What is the typical scope of such a project?
A first portal module can be up and running within a few sprints. For a module alongside an EHR with FHIR integrations, audit logging, a DPIA and penetration testing, we're looking at a project spanning several sprints. A research or AI platform with pseudonymisation, MDR overlap and extensive governance is a longer project, and we plan it phase by phase and review progress along the way. This is similar to our approach to healthcare software more broadly.
Do you work together with our DPO, CISO and quality function?
Always. An NEN 7510 project without a DPO or CISO at the table does not work: they hold ultimate responsibility for the standard. We deliver architecture documents, DPIA input and mapping tables in a form that suits their review process, and we schedule working sessions at the start and at every major architectural decision. We also liaise directly with an external NEN auditor.
What does an NEN 7510-compliant project cost?
That depends heavily on scope: a single portal module has a different price from a research platform with AI and MDR. We work with sprint budgets and, after the scoping session, provide a reasoned estimate per phase. The compliance overhead — DPIA, mapping, penetration testing, sub-processor management — is a fixed part of every phase, not an afterthought. For enterprise contexts the same approach applies as for our enterprise software projects.

Talk to us about your NEN 7510 project.

A no-obligation introductory call of half an hour. We listen to your healthcare context (which data, which EHR, which partners) and give you direction on where the compliance risks and solutions lie. No sales pitch, just concrete advice. We also carry out similar compliance projects for KYC/AML compliance in other regulated sectors.

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