Skip to content
DentalSystemsQuality, Security, Transparency

FADP & Cybersecurity Guide · interactive version

Is your practice ready for the FADP?

The DentalSystems guide in 22 points. For each one: what the law and good practice require, a question about your practice, and an answer explained according to your situation.

About 10 minutesAnswers saved in your browser only

The essentials in 30 seconds

  • It is the practice, its owner or the company that runs it, that is responsible for its patients' data. Not your IT provider, not your software vendor.
  • X-rays, diagnoses, treatment plans: this is health data, which the law classifies as sensitive data.
  • The law requires you to know where this data is, to protect it, to report a serious leak and to be able to show what you have put in place.
  • Fines, of up to CHF 250,000, target individuals and intentional violations, most often following a complaint. Negligence is not punished under this act, but an incident is costly in other ways.
  • In the event of an attack: unplug, call, do not pay, document, report.

The interactive check-up requires JavaScript. The explanations for each point remain readable below.

The law and your patients

The revised FADP has applied to every practice, whatever its size, since 1 September 2023. Four obligations to know.

Point 1Essential

Knowing where your data is

Patient files, X-rays, appointment book, e-mails, backups, paper: the law requires you to know where your patients' data is and how it is protected. Everything else builds on this.

Learn more

The most common blind spots: an old hard drive never wiped, a USB stick in a drawer, the laptop that goes home in the evening, the files sent to the laboratory, an assistant's phone.

Companies with fewer than 250 employees are in principle exempt from keeping a record of processing activities, unless they process sensitive data on a large scale. Keeping one is still the simplest way to show that you know where your data is.

Do you have an up-to-date list of every place where your patients' data is kept?

Guide, chapter 1Template DS8: record of processing activities

Point 2Important

Informing your patients

Your patients must know what data you collect, why, how long you keep it and to whom you pass it on: laboratory, insurers, specialists. That is the purpose of the data protection notice.

Learn more

The law requires patients to be informed when their data is collected (Art. 19 FADP). The notice can be on your website, displayed in the waiting room or handed out with the medical history questionnaire.

Intentionally failing to provide this information is punishable by a fine, if the patient files a complaint.

Do your patients receive clear information about how their data is used?

Guide, chapter 1Template DS9: notice for patients

Point 3Important

Answering an access request

Any patient can ask you what data you hold about them. You must answer free of charge, completely, and in principle within 30 days.

Learn more

The practice remains responsible for the answer, even if the data is held by a provider: you cannot refer the patient to your IT provider. Check the requester's identity before sending anything.

Never answer "we found nothing" if data exists: in Zurich, in 2025, an answer of this kind earned its author a fine.

If a patient asked tomorrow for a copy of all their data, could you answer completely within 30 days?

Guide, chapter 1Template DS10: reply to an access request

Point 4Essential

Reporting a data breach

If a leak or an attack is likely to result in a high risk for your patients, you must report it to the Federal Commissioner (FDPIC) as soon as possible. There is no fixed deadline like the European 72 hours, but you must act quickly.

Learn more

The report is made online, at databreach.edoeb.admin.ch: what happened, the consequences, the measures taken. It cannot be used against you in criminal proceedings without your consent.

Your IT provider must notify you as soon as possible of any breach it detects. If the protection of patients requires it, they must also be informed.

Keep a written record of every incident: the facts, the consequences, the measures taken. Breaches are documented, and the record is kept for at least two years from the report (Art. 15 para. 4 DPO).

Do you know who, in the practice, decides to report a leak to the FDPIC, and how to do it?

Guide, chapters 1 and 16Quick-reaction sheet DS2

Communications

E-mails, messages, paper: this is how most data leaves the practice.

Point 5Essential

E-mails containing patient data

An X-ray, a diagnosis or any information that identifies a patient is never sent by ordinary e-mail. You need encrypted e-mail, such as HIN within the healthcare network, or Proton.

Learn more

Gmail, Hotmail or Bluewin do not encrypt the content end to end: the message can be read on the servers it passes through, sometimes outside Switzerland.

With Proton, end-to-end encryption is automatic between Proton users; to any other address, you send a password-protected e-mail, with the password passed on by another channel. The subject line is never encrypted: never write a patient's name in it.

Is the patient data you send by e-mail always sent through encrypted e-mail?

Guide, chapter 2

Point 6Essential

WhatsApp, text messages and personal phones

Sending a photo of an X-ray to a colleague by WhatsApp takes seconds. But it is health data leaving the practice, on a personal device.

Learn more

WhatsApp encrypts messages, but the photos remain in the phone's gallery, are often backed up to a personal cloud, and the phone can be lost, stolen or lent.

Professional secrecy applies to the dentist and their assistants: anyone who intentionally discloses patient data incurs personal criminal liability (Art. 321 SCC, Art. 62 FADP). The practice owner, for their part, must be able to show that clear rules were in place.

Is it clear to the whole team that no patient data goes through WhatsApp, text messages or a personal phone?

Guide, chapter 14Template DS3: security policy

Point 7Recommended

Paper documents

Not all leaks are digital. A file left on the reception desk or an X-ray thrown in the bin is also a breach of secrecy.

Learn more

The guide recommends a shredder for any document containing patient data, no file visible from reception, and screens turned away or fitted with a privacy filter where the waiting room can see them.

Are documents containing patient data shredded and never visible from reception?

Guide, chapter 14

Computers and network

A single vulnerable device is enough to expose the whole practice.

Point 8Essential

Devices that still receive security updates

The law requires systems and software that are always up to date in terms of security (Art. 3 DPO). Windows 10 has no longer received security updates since 14 October 2025, except with a paid extended security updates subscription. Any device that no longer receives them is an open door, and one is enough.

Learn more

Known vulnerabilities are publicly listed, and automated tools exploit them. From one vulnerable computer, an attacker moves on to the server, the backups and the practice software, often at night or at the weekend.

Running Windows 11 is not enough: each version has its end date. Windows 11 24H2, Pro edition, has no longer received security updates since 13 October 2026.

Automatic updates and a restart every week take care of most of it. Think also of forgotten devices: an old server, a printer, the WiFi router. A medical device that can no longer be updated must be isolated from the rest of the network. We recommend replacing computers every five years at most.

Do all your computers and servers still receive security updates, and install them automatically?

Guide, chapters 3 and 12

Point 9Important

Encrypted drives

A laptop stolen from a car, a server taken in a burglary: without encryption, all the data can be read by anyone.

Learn more

Encryption is built into Windows Pro (BitLocker) and macOS (FileVault) at no extra cost. It makes the drive unreadable without its key.

The recovery key must be kept in a safe place, not on the computer itself: without it, a simple fault can make the data inaccessible.

Are the drives of your computers, laptops and server encrypted?

Guide, chapter 6

Point 10Important

A separate WiFi for patients

A patient's phone connected to the practice WiFi must never be able to reach your computers or your server.

Learn more

The guide recommends separate networks: one for the computers and the server, one for medical devices if needed, and one for guests, limited to the internet.

The password of the practice network is never displayed in the waiting room. WPA3 encryption is recommended; WPA2 is the minimum.

Is the WiFi offered to patients separate from the network of your computers and your server?

Guide, chapter 7

Point 11Essential

Protection that monitors, not just an antivirus

An antivirus mainly blocks what it already knows, and no one sees its alerts. Protection known as EDR watches what programs do, stops an attack in progress, even an unknown one, and alerts a professional.

Learn more

If a program starts encrypting folders one after another, the EDR blocks it, isolates the computer and alerts the provider.

An EDR is only worth anything if it is monitored: someone must receive the alerts and react quickly.

Are your computers protected by an EDR solution whose alerts are followed up by your provider?

Guide, chapter 11

Backups

On the day everything is locked, your backup decides whether you reopen the next day or in a month.

Point 12Essential

A copy outside the practice

The 3-2-1 rule: three copies of your data, on two different media, one of them outside the practice. A fire, water damage or a burglary must not take all the copies at once.

Learn more

The copy outside the practice must be encrypted, automatic and recent, and be located in a country that offers adequate protection, ideally in Switzerland.

A drive taken home every evening works as long as no one forgets, which always ends up happening.

Is a complete, recent copy of your data kept outside the practice?

Guide, chapter 4

Point 13Essential

A copy that an attack cannot erase

Ransomware looks for backups so as to encrypt them first. A drive that is permanently connected will be encrypted along with everything else.

Learn more

The answer: a disconnected copy, or one locked so that no one can modify or delete it for a certain time, not even a program that has taken control of the network. This is called an immutable copy.

It is the recommended complement to the 3-2-1 rule; it is sometimes written 3-2-1-1-0: one more immutable copy, and zero errors in restore tests.

Is at least one of your backups disconnected, or protected against modification and deletion?

Guide, chapter 4

Point 14Essential

A restore that has actually been tested

A backup that has never been restored is a promise, not a guarantee. The law requires you to be able to restore access to the data quickly after an incident (Art. 3 DPO).

Learn more

A test consists of restoring a few patient files or X-rays and checking that they open normally.

At least once a year, ideally more often; each test is recorded with its date and result. This is also what you will be asked for after an incident.

Has a restore of your data been tested, successfully, in the last twelve months?

Guide, chapter 4

Access

Who can get into your systems, and with which key.

Point 15Important

One account per person

A shared account, such as "reception" or "practice", makes it impossible to know who did what. Everyone must have their own account, with only the access their work requires.

Learn more

An assistant does not need the accounts, an external accountant does not need the X-rays: if an account is stolen, the attacker only gets what that account allows.

When a member of staff leaves, all their access is cut off the same day: computer, e-mail, software, remote access. Reviewing the list of accounts every quarter prevents forgotten access from piling up.

Does each member of staff have their own account, and is the access of former staff cut off on the day they leave?

Guide, chapter 10Template DS6: rules for temporary staff

Point 16Important

Strong passwords, kept in a vault

A short password, the name of the practice or a date of birth can be guessed in seconds. The guide recommends at least twelve characters and a different password for each service, stored in a password manager.

Learn more

A password manager keeps all the credentials encrypted: you only need to remember one. It does away with notes stuck under the keyboard and with the same password everywhere, the cause of many chain hacks.

Are the practice's passwords long, different for each service, and stored in a secure password manager?

Guide, chapter 5

Point 17Essential

Two-factor authentication

After the password, a code on the phone: even if the password is stolen, the attacker stays outside. It is the same principle as a bank card and its PIN.

Learn more

Enable it first on e-mail, remote access, online backups, the dental software if it allows it, and the bank.

A hacked mailbox is often used to deceive your contacts, laboratories and patients included.

Is two-factor authentication enabled on the practice's e-mail, remote access and online services?

Guide, chapter 5

Point 18Essential

Remote access

A remote control tool left permanently open, with a weak password, is a classic way in for ransomware.

Learn more

Every connection must be identified, protected by two-factor authentication, logged and limited in time. The wider the access (server, patient data), the more secure the solution must be.

The free versions of remote control tools are not designed for this.

Does remote access to your computers go only through a professional tool, with two-factor authentication and a record of every connection?

Guide, chapter 8

Organisation

The contracts, rules and reflexes that hold everything else together.

Point 19Essential

An agreement with every provider

Your IT provider, your hosting provider, your fiduciary: any provider that processes your patients' data on your behalf must be bound by a data processing agreement (Art. 9 FADP).

Learn more

The agreement sets out what the provider may do with the data, how it protects it, to whom it may entrust it and what happens to it at the end of the relationship.

Before entrusting your data, you must also make sure that the provider is able to protect it. Intentionally entrusting data without complying with these rules is punishable, if a complaint is filed.

Do you have a signed data processing agreement with every provider that accesses your patients' data?

Guide, chapter 13Template DS7: data processing agreement

Point 20Important

Written rules and an aware team

A large share of attacks begin with a booby-trapped e-mail or a deceptive phone call, received in good faith. Written, signed security rules and a short awareness session every year are the best defences.

Learn more

The written rules cover computers, passwords, e-mail, personal devices and what to do in the event of an incident. Every member of staff signs them on arrival.

The awareness session, 30 to 60 minutes long, takes place at least once a year and for every newcomer; a record of it is kept (date, participants, topics). The quiz on this site lets everyone test their reflexes.

Has your team signed written security rules and attended an awareness session in the last twelve months?

Guide, chapter 14Template DS3: security policyTemplate DS4: training certificateFADP quiz

Point 21Essential

Knowing what to do in an attack

The first minutes count. Everyone in the practice must know what to do, and above all what not to do, if a screen displays a ransom demand:

  1. Isolate: unplug the network cable and turn off the WiFi. Do not switch the computer off.
  2. Call your IT provider; failing that, the Federal Office for Cyber Security (FOCS).
  3. Do not pay the ransom: that is the Confederation's recommendation.
  4. Document: photograph the screens, note the exact time, delete nothing.
  5. Assess: is patient data affected?
  6. Report to the FDPIC if the risk for patients is high.

Is the procedure to follow in the event of an incident displayed in the practice and known to the whole team?

Guide, chapter 16Quick-reaction sheet DS2Template DS5: incident procedureForm DS11: incident documentation

Point 22Recommended

Cyber insurance

Cyber insurance covers part of the costs of an incident: recovery, business interruption, assistance. It complements security; it does not replace it.

Learn more

Read the exclusions and the preconditions: some policies do not pay out if updates had not been installed or if backups were missing.

Also check the excess, the coverage limit, and whether assistance can be reached at any hour.

Do you have cyber insurance, and do you know its conditions and exclusions?

Guide, chapter 15

YOUR DETAILED CHECK-UP

Where does your practice stand?

No answers yet

Answer the points above: your check-up builds up as you go.

To fix

    To check

      In order

        Send us this check-up

        "Send us this check-up" opens the contact form with this summary: you read it over, complete it and decide whether to send it. This check-up helps you take stock; it replaces neither an audit nor legal advice.

        Call+41 77 245 48 44
        ↑↓ BrowseEnter Open