TOOLBOX · COMPLIANCE & NIS2
Maturity Check Medical Practices.
Health data need special protection. 12 questions for medical practices and doctors’ offices based on GTelG 2012, the Austrian Physicians Act and BSI IT-Grundschutz, with an immediate maturity level, measures and sources.
HOW THE CHECK CALCULATES
Traceable
Instead of Gut Feeling.
12 questions, at most 25 points. The measures are based on the sources named, and individual implementation examples are recommendations by TOMORIS; weights and levels are an assessment by TOMORIS based on the effect of a measure.
- 01
Answers Become Points
Yes counts 1, Partially 0.5 and No 0 points, each multiplied by the weight of the question. If you do not know, choose No.
- 02
Weight by Effect
Key measure (3, here 4×): Directly protects against the most serious consequences of an attack or outage: data loss, standstill or the takeover of accounts and access. Important measure (2, here 5×): Makes an incident less likely or limits its extent and duration. Foundation (1, here 3×): Organizational prerequisite that works through the other measures, such as responsibility, overview or documentation.
- 03
Percentage and Level
Points reached divided by possible points, rounded down to whole percent. Level 1 Getting Started: 0 to 39 percent. Level 2 Foundations: 40 to 69 percent. Level 3 Advanced: 70 to 89 percent. Level 4 Established: from 90 percent.
- 04
Key Measures Set a Limit
If a key measure is answered with No, the maturity level stays at level 2 at most, even if the percentage is higher. The report lists the open measures sorted by weight.
BASIS
What the
Questions Are Based On.
Health data are special categories of personal data (Article 9 GDPR). Physicians and their assistants are bound by professional secrecy (Section 54(1) ÄrzteG 1998); records must be kept for at least ten years (Section 51(3)).
For healthcare providers, the Health Telematics Act 2012 governs data security in the electronic transmission of health data and requires all data security measures to be documented on the basis of an IT security concept (Sections 3 to 8 GTelG 2012).
For the technical measures, the BSI IT-Grundschutz Compendium, Edition 2023, serves as a model. It is a framework of the German Federal Office for Information Security (BSI) and not a legal obligation in Austria. Whether NISG 2026 applies to your practice depends on activity and size; check this with the NIS2 check.
- LEGAL SOURCE
Health Telematics Act 2012 (GTelG 2012), Section 8 (RIS, German)
Citations: Section 8 para. 1; Section 8 para. 1 to 3.
Go to Source - LEGAL SOURCE
Physicians Act 1998 (ÄrzteG 1998), Section 54 (RIS, German)
Citations: Section 54 para. 1.
Go to Source - LEGAL SOURCE
Health Telematics Act 2012 (GTelG 2012), Section 2 (RIS, German)
Citations: Section 2 item 3 and 4.
Go to Source - LEGAL SOURCE
Health Telematics Act 2012 (GTelG 2012), Section 6 (RIS, German)
Citations: Section 6 para. 1 and 3.
Go to Source - LEGAL SOURCE
Regulation (EU) 2016/679 (GDPR), consolidated version
Citations: Art. 9 para. 1 and Art. 32 para. 1 lit. a; Art. 32 para. 1 lit. c; Art. 28 para. 3; Art. 33 para. 1.
Go to Source - LEGAL SOURCE
Physicians Act 1998 (ÄrzteG 1998), Section 51 (RIS, German)
Citations: Section 51 para. 3; Section 51 para. 5.
Go to Source - MODEL · BSI
BSI: IT-Grundschutz Compendium, Edition 2023 (German)
Citations: ORP.4.A1, ORP.4.A2 and ORP.4.A9; SYS.2.1.A1; OPS.1.2.5.A17, ORP.4.A10 and ORP.4.A21; CON.3.A5, A12, A14 and A15; OPS.1.1.3.A1, OPS.1.1.3.A2 and OPS.1.1.3.A15; NET.1.1.A4, NET.1.1.A5 and NET.1.1.A6; OPS.1.2.5.A2, OPS.1.2.5.A3 and OPS.1.2.5.A19; CON.6.A2 and CON.6.A12; ORP.3.A3, ORP.3.A6 and OPS.1.1.4.A7; DER.2.1.A1 to A4.
Go to Source - MODEL · BSI
BSI: Two-factor authentication (German)
Citations: sections “Bitte nicht: Die Zwei-Faktor-Authentisierung deaktivieren” (do not deactivate two-factor authentication) and “Empfehlungen” (recommendations).
Go to Source
More on the Healthcare & medical practices industry · NIS2 Applicability Check (German) · All Downloads
QUESTIONS
Good to Know.
How is the maturity level calculated?
Each answer gives points: Yes 1, Partially 0.5, No 0, multiplied by the weight of the question (key measure 3, important measure 2, foundation 1). This checklist has 12 questions and at most 25 points. The points reached give a percentage, rounded down, which determines the level: level 1 Getting Started 0 to 39 percent, level 2 Foundations 40 to 69 percent, level 3 Advanced 70 to 89 percent, level 4 Established from 90 percent. If a key measure is answered with No, the maturity level stays at level 2 at most.
Where do the questions come from?
From the Health Telematics Act 2012, the Physicians Act 1998, the GDPR and the BSI IT-Grundschutz Compendium, Edition 2023. The Compendium is a framework of the German Federal Office for Information Security (BSI) and not a legal obligation in Austria; it serves as a model for the technical measures. Every question names its citation.
What does the GTelG 2012 require of a medical practice?
Healthcare providers may only transmit health data electronically if the identity of the patients and of the healthcare providers involved, their roles, and confidentiality and integrity are ensured (Section 3(4)). Confidentiality is ensured by networks secured according to the state of the art that provide at least cryptographic or structural protection, access only for a closed or definable user group and authentication, or by procedures that achieve full encryption (Section 6(1)). In a processor’s cloud storage, health data may only be stored in encrypted form (Section 6(3)). All data security measures must be documented on the basis of an IT security concept (Section 8(1)).
Does NIS2 apply to medical practices?
That depends on activity and size. Healthcare providers are listed in Annex 1 of NISG 2026; as a rule they are covered if they are at least a medium enterprise, that is from 50 employees or with an annual turnover and annual balance sheet total of more than EUR 10 million, with partner and linked enterprises generally counted as well (Sections 24 and 25). In exceptional cases, the cybersecurity authority can also classify smaller entities by decision (Section 26). Whether this applies to your practice can be checked with the NIS2 applicability check.
Is the result proof or legal advice?
No. The check is a self-assessment based on your answers. It does not replace an audit or legal advice and does not prove that legal or professional requirements are met. The weights and levels are an assessment by TOMORIS; the measures are based on the sources named, and individual implementation examples are recommendations by TOMORIS.
Are my answers transmitted or stored?
No. The questionnaire and evaluation run entirely in your browser; your answers are neither transmitted to TOMORIS nor to third parties and are not stored, not even on your device. Only when you choose “Discuss the Result” does the contact form take over industry and maturity level as the topic, not your individual answers.
How do I save the report as a PDF?
In the report, choose “Print or Save as PDF” and select “Save as PDF” or “Microsoft Print to PDF” as the printer in the print dialog. Only the report is printed, in light colors even in dark mode.
TOOLBOX
More
Tools.
NIS2 applicability check
Am I affected? In 3 minutes
View (German)Maturity Check for Municipalities
How well is your municipal office protected? 13 questions based on the BSI profile for municipal administrations, IT-Grundschutz and the GDPR, with an immediate maturity level, measures and sources.
ViewMaturity Check for Law Firms
Confidentiality needs secure IT. 12 questions based on professional law, the GDPR and BSI IT-Grundschutz, with an immediate maturity level, measures, sources and matching templates.
View
YOUR NEXT STEP
You Have the Result.
What Comes Next?
We assess findings, prioritize by risk and put changes into practice on request: as a project with EXPERTS or as ongoing operations with GRID.