HDS datacenters: certified for French health data
Hosting personal health data in France is regulated by law. HDS - Hébergeur de Données de Santé - is the certification that makes it legal, and it reaches all the way down into the datacenter itself.
What is HDS certification?
HDS (Hébergeur de Données de Santé) is the French certification required by law - Article L.1111-8 of the Public Health Code - for any organization hosting personal health data collected in the course of care in France. The framework is governed by the Agence du Numérique en Santé (ANS), with certificates issued by accredited certification bodies. Unlike voluntary ISO standards, HDS is a legal precondition: hosting in-scope health data without it is an offence.
The certification is built on international standards - its core is ISO 27001, extended with requirements drawn from IT service management and cloud privacy practice, plus health-sector-specific obligations. The referential was substantially revised in 2024, notably strengthening data sovereignty: certified hosting must take place within the European Economic Area, with transparency obligations on any transfer of data outside it.
HDS decomposes hosting into six certifiable activities, from the physical layer up: (1) provision of physical sites - the datacenter itself, (2) physical hardware infrastructure, (3) virtual infrastructure, (4) software platform hosting, (5) administration and operation of the information system, and (6) data backup. Certificates cover the specific activities an organization performs - a datacenter operator typically certifies activities 1 and 2 as a physical infrastructure host, while cloud and managed-service providers certify the higher layers.
Why HDS matters for datacenter operators
France's health sector is digitalizing at speed - hospital systems, imaging archives, telemedicine platforms, research datasets - and every byte of it legally requires HDS-certified hosting. For datacenter operators, activities 1 and 2 certification opens this entire regulated market: hospitals, software vendors and cloud providers serving French healthcare can only build on certified physical infrastructure.
The certification chain is what makes the datacenter's position strategic. A SaaS vendor certifying activities 5 and 6 must stack its services on providers certified for the layers beneath; an uncertified facility breaks the chain for every customer above it. HDS-certified datacenter capacity is consequently scarcer and commands stronger commercial terms than generic colocation.
Because HDS embeds ISO 27001, the path is shorter than it looks for a well-run facility. An operator already certified ISO 27001 with the right scope has done most of the heavy lifting; HDS adds the health-data-specific requirements, the sovereignty obligations and the contractual framework. Conversely, designing a new facility for HDS from day one bakes in a durable regulatory moat at marginal cost.
Core HDS requirements for a datacenter
For physical-layer hosting (activities 1 and 2), the requirements concentrate on the facility and its operation:
- ISO 27001 foundation
- A certified ISMS covering the hosting activities is the base layer - HDS audits are built on top of it, with the health-data scope explicit in the scope statement.
- Physical security of health data spaces
- Layered access control, surveillance and traceability for the spaces hosting health data, with controls demonstrably stricter where certified activities are delivered.
- EEA hosting and sovereignty
- Health data hosted within the European Economic Area, with documented transparency on any data flows and on the legal exposure of the hosting entities.
- Service management discipline
- Documented service levels, incident, change and capacity management for the hosting service - requirements drawn from IT service management practice.
- Health-data-specific contracts
- Mandatory contractual clauses with customers: defined responsibilities, data restitution and reversibility at end of contract, breach notification and audit rights.
- Traceability and logging
- Access to systems and spaces hosting health data logged and retained, supporting both the certification audit and the operator's regulatory accountability.
- Subcontractor chain control
- Every subcontractor in the hosting chain identified and bound to the requirements - the certification chain must be continuous from facility to application.
How to build an HDS-compliant datacenter
For a facility targeting activities 1 and 2 - the physical layers of the HDS chain - the build sequence looks like this:
Define the certified perimeter
Decide which halls, rooms and services will host health data and write the scope accordingly. A clearly bounded perimeter simplifies both the build and every audit that follows.
Design physical controls to the strictest tenant
Health data spaces need demonstrably controlled access: zoning, individual traceability, surveillance coverage and visitor regimes designed in from the architectural stage.
Establish the ISO 27001 base
Stand up and certify the ISMS with the hosting scope - or extend an existing certificate. Every HDS control maps onto this foundation, so its quality determines the whole project's pace.
Add the HDS-specific layer
Sovereignty documentation, health-data contractual framework, service management procedures and the activity-specific requirements for physical site and hardware provision.
Lock the subcontractor chain
Maintenance, security and logistics providers operating in the certified perimeter must be contractually bound to the requirements, with access governance to match.
Pass the combined audit
An accredited certification body audits the ISO 27001 base and the HDS-specific requirements together. The certificate runs on a three-year cycle with annual surveillance audits.
Maintain the referential watch
The HDS framework evolves - the 2024 revision tightened sovereignty obligations with transition deadlines. Track ANS publications and fold changes into the management review cycle.
How Circular Datacenter builds for HDS
As a French datacenter design and build company, HDS is home territory. We design facilities - and retrofit existing ones - with the certified perimeter, physical control topology and traceability infrastructure that activities 1 and 2 require, aligned with the current ANS referential from the first drawing.
Because HDS rides on ISO 27001, our security-by-design approach serves both at once: the zoning, access control and documentation we deliver for the ISMS is engineered to carry the HDS layer without rework. For operators extending an existing facility into health data hosting, we scope the works to the certified perimeter so the rest of the site keeps running untouched.
Our circular workflows are built for regulated environments: equipment decommissioning, sanitization and re-use inside an HDS perimeter follow documented chain-of-custody procedures, so lifecycle value recovery never compromises the certification your health-sector customers depend on.
Frequently asked questions
What is an HDS certified datacenter?
It is a facility certified under the French HDS framework for hosting personal health data - typically for activities 1 and 2: provision of the physical site and of hardware infrastructure. Certification is issued by accredited bodies against an ANS referential built on ISO 27001, and is legally required for health data collected during care in France.
Who needs HDS certification?
Any organization hosting personal health data collected in the course of care in France - datacenter operators, cloud providers, SaaS vendors and managed service providers - for the activities they actually perform. Each layer of the hosting chain needs certification for its own activities, resting on certified providers beneath it.
What are the six HDS activities?
(1) Provision of physical sites, (2) provision of hardware infrastructure, (3) provision of virtual infrastructure, (4) provision of the software platform, (5) administration and operation of the information system, and (6) data backup. Datacenter operators typically certify activities 1 and 2; service providers certify the layers above.
How does HDS relate to ISO 27001?
ISO 27001 is the mandatory foundation: HDS certification audits an ISO 27001 ISMS extended with health-specific requirements - sovereignty of hosting, mandatory contractual clauses, service management discipline and activity-specific controls. An operator already holding ISO 27001 with the right scope has completed most of the path to HDS.
Can health data hosted under HDS leave the EU?
The revised HDS referential requires hosting within the European Economic Area and imposes transparency obligations on any transfer of health data outside it, alongside disclosure of the hosting entities' exposure to non-EU law. In practice, certified hosting chains keep French health data on EEA soil.
Related certifications
Contact our teams