(Disclaimer: Please note: Talsec is a commercial, community-driven organization independent of the BSI or other regulatory bodies. The information presented reflects our interpretation based on publicly available data, Talsec product capabilities, and community insights; official interpretations may differ, for which Talsec assumes no liability.)
Introduction: Navigating the Complex Web of HealthTech App Security in the EU
The European Union presents a significant opportunity for HealthTech innovation, but it also comes with a complex regulatory landscape designed to protect sensitive patient data and ensure the trustworthiness of digital health solutions. Regulations like the General Data Protection Regulation (GDPR), the Medical Device Regulation (MDR), the Network and Information Systems Directive (NIS 2), and the upcoming Cyber Resilience Act (CRA) impose stringent requirements on how health applications are designed, developed, deployed, and maintained.
These regulations emphasize principles like data minimization, security by design, robust risk management, secure data handling throughout the lifecycle, and resilience against cyber threats. While overarching EU laws set the framework, specific technical guidelines, such as Germany's BSI TR-03161 for digital health applications (DiGA), provide concrete benchmarks for security measures. Meeting these diverse and demanding requirements can be a significant challenge, especially for startups and scale-ups.
Talsec provides a suite of mobile security solutions specifically designed to help HealthTech companies address these challenges head-on, embedding security and compliance into their mobile applications. This article explores key requirement areas relevant across the EU, exemplified by TR-03161 objectives, and demonstrates how Talsec's SDKs help achieve compliance.
1. Intended Use and Data Minimization
A core principle strongly emphasized by GDPR is ensuring that applications only collect and process data necessary for their legitimate purpose. Unnecessary data collection or sharing, especially with third parties, increases risk and violates regulatory principles.
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O.Purp_2 The application MUST NOT collect and process data that does not serve the legitimate purpose of the application. |
Talsec Premium subscription and SDK allows configuring the target end-points for threat logs data collection. Thus, customer can decide which data to store and process (if at all). |
O.Purp_7 If the application uses third-party software, all functions used MUST be necessary for the legitimate purposes of the application. O.Purp_8 Unless it is necessary for the primary or legitimate purpose of an application, sensitive data MUST NOT be shared with third parties. |
Talsec offers optional service App Scanning (SAST/DAST) and provides report with verification of 3rd party components and corresponding end-points which they are sending data. |
2. Secure Architecture and Design
EU regulations like the MDR and the CRA mandate a "secure by design" approach. This means building security into the application architecture from the outset, protecting data throughout its lifecycle, securing interfaces, and ensuring the application's integrity and authenticity.
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O.Arch_2 Already in the design phase of the application… The architecture of the application MUST ensure the secure collection, processing, storage and deletion of sensitive data in a data lifecycle. |
Configurability of data collection by Premium SDK. |
O.Arch_5 Security functions MUST always be implemented on all external interfaces and API endpoints. |
AppiCryptⓇ SDK provides strong and simple to integrate API protection |
O.Arch_6 The application MUST enable the verification of integrity by means of a digital signature. The authenticity of the application is ensured by the trustworthiness of the source (see A.Source) is ensured. |
RASP+ implements App integrity control |
O.Arch_11 The developer MUST choose a source for publishing the application (and its updates) that protects the application against tampering by unauthorized parties and provides a trusted channel for obtaining the application. |
RASP+ implements Source of App Installation control |
3. Source Code Protection
Protecting the application's source code itself through techniques like obfuscation is crucial for preventing reverse engineering, which could expose vulnerabilities or intellectual property.
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O.Source_9 Modern security mechanisms such as obfuscation and stack protection SHOULD be activated to build the application. |
Talsec verifies if Basic Class name obfuscation is applied at build time of the App. Talsec implements Strings Obfuscation by Hardening SDK Secure Vault feature. |
4. Managing Third-Party Software Risks
HealthTech apps often rely on third-party libraries. Ensuring these components are up-to-date, from trusted sources, and free from vulnerabilities is vital for overall application security and compliance, a concern amplified by supply chain security requirements in NIS 2 and CRA.
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O.TrdP_2 - Third-party software MUST be used in the latest version or the previous version intended for publication. |
Talsec delivers SDK and artifacts to private Repo. Updates of the SDK will be visible in the IDE |
O.TrdP_5 - Trustworthiness of the source of third-party software. |
Talsec offers optional service App Scanning (SAST/DAST) and provides report with verification of 3rd party |
5. Cryptography and Key Management
Strong cryptography is fundamental to protecting sensitive health data, both at rest and in transit. Regulations demand that cryptographic keys are stored securely and operations are performed in protected environments.
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O.Cryp_6 All cryptographic keys SHOULD be stored in an environment protected against manipulation and disclosure. |
Talsec Hardening SDK Secure Vaulting feature for protection of keys from Reverse engineering and Static Code Analysis |
O.Cryp_7 All cryptographic operations SHOULD take place in an environment protected from manipulation and disclosure. |
RASP+ is the tool to protect the execution Environment |
6. Robust Authentication
Ensuring that only legitimate users and systems can access data and functionality is paramount. This involves state-of-the-art authentication mechanisms for backend connections and protecting the authentication process itself from attacks like session hijacking or API abuse.
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O.Auth_6 The user SHOULD be given the option of being informed about unusual login processes. O.Auth_12 The application MUST use state-of-the-art authentication for the connection of a backend system. |
Talsec AppiCryptⓇ SDK and Hardening SDK provides protection from following attack vectors on the Authentication process:
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O.Cryp_7 All cryptographic operations SHOULD take place in an environment protected from manipulation and disclosure. |
RASP+ is the tool to protect the execution Environment |
7. Data Security at Rest and In Use
Beyond encryption, data security involves protecting sensitive information when stored locally and preventing unauthorized access or exposure while the app is running (e.g., via screenshots, screen sharing, or overlay attacks).
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O.Data_3 The application SHOULD store sensitive data in an area specially protected against access and manipulation. |
RASP+ protects Execution Environment and sandbox Hardening SDK implements secure vault for keys |
O.Data_13 The application MUST use functions of the operating system to prevent the display of sensitive data and access for third parties. This also includes the storage of the screen (e.g. screenshots and displays for app switching). |
RASP+ implements protection against: Screencast / screenshot Screen Overlay attack Screen Tapjacking |
O.Data_15 The application MUST encrypt locally stored data with a secure device binding. |
AppiCrypt can detect Device exchange of the given User Local encryption of storage needs to be done by local Device generated keys that can be protected by Secure Vaulted key if the local HW security module is disabled. |
8. Secure Network Communication
Protecting data in transit is critical. This requires using secure communication channels, validating server identities robustly (e.g., via certificate pinning), and protecting against Man-in-the-Middle (MiTM) attacks.
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O.Ntwk_3 Secure communication channels only with operating system functions or security-checked third-party software. |
Hardening SDK protects against MiTM RASP+ can detect if VPN software is applied to prevent unintentional usage. |
O.Ntwk_4 The application MUST use certificate pinning. O.Ntwk_5 The application MUST check the server certificate of the backend system. |
Hardening SDK protects against MiTM by Dynamic TLS Pinning feature. |
9. Platform-Specific Interactions
Mobile security involves interacting with underlying platform security features, such as device locks, and carefully managing how sensitive data might be exposed through notifications or screen sharing.
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O.Plat_1 the end device SHOULD have activated device protection (password, pattern lock, etc.) |
RASP+ and AppiCrypt can detect missing ScreenLock |
O.Plat_4 MUST NOT include sensitive data in messages or notifications that have not been explicitly enabled by the user (see O.Plat_5). |
RASP+ protects against an unintentional screen sharing |
10. Application Resilience and Runtime Protection
Modern mobile threats often target the application at runtime. Regulations increasingly expect apps to defend themselves against reverse engineering, tampering, debugging, and execution on compromised environments (e.g., rooted/jailbroken devices). This aligns with the enhanced risk management focus of NIS 2.
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O.Resi_2 Detection of the operating status of the mobile device used. |
RASP+ protects against Root/Jailbreak |
O.Resi_3 The application MUST implement its own checking mechanisms to determine whether it is running in a development/debug environment when the application is started. |
RASP+ protects against Dev mode and Debuggers enabled
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O.Resi_4 The Application MUST implement its own checking mechanisms to determine whether the application has been started under unusual user rights. If the application detects that this is the case, it MUST exit immediately. O.Resi_5 The application SHOULD ensure the integrity of the end device before processing sensitive data. |
RASP+ detects compromised app sandbox and execution environment and can KILL the app immediately |
O.Resi_7 The application SHOULD implement hardening measures, such as an integrity check before each processing of sensitive data within the program flow. |
RASP+ detects app Integrity compromise and tampering with |
O.Resi_8 The application MUST implement state of the art measures against reverse engineering. |
RASP+ AppiCrypt implements strong award winning solution to combat reverse engineering and RASP bypassing prevention. |
Conclusion: Simplify Compliance and Enhance Security with Talsec
Navigating the EU's complex regulatory environment for HealthTech app security requires a proactive, multi-layered approach. While compliance frameworks like GDPR, MDR, NIS 2, and CRA set the standards, and technical guidelines like TR-03161 provide specifics, implementation remains a challenge.
Talsec's SDKs offer a powerful way to address a broad spectrum of these security requirements directly within your mobile application. By integrating solutions for runtime protection (RASP+), API security (AppiCrypt®), and Hardening, Talsec helps HealthTech companies:
By embedding security throughout the application lifecycle, Talsec empowers HealthTech innovators to confidently build and deploy trusted digital health solutions in the demanding European market.