Dubai clinics · UAE patient photo storage

Clinical Photo Management Software with UAE Data Residency

CureCast helps plastic surgeons, dermatologists, wound care surgeons, pediatric surgeons and medical spas in Dubai organize patient photos and compare results across visits. Its UAE deployment uses Microsoft Azure UAE North in Dubai for primary storage and an active secondary copy in UAE Central, Abu Dhabi.

By Vishal Parikh, Founder, CureCast · Updated October 30, 2026 · For DHA-licensed practices

Clinical photo software for Dubai clinics

CureCast is clinical photo management software for Dubai practices that need to organize patient photographs, compare before-and-after results and evaluate UAE data residency. Plastic surgeons, dermatologists, wound care surgeons, pediatric surgeons, medical spas and other surgical teams can review the photo workflow alongside storage and access requirements.

Plastic surgeons

Keep baseline and follow-up photography attached to the patient record. Select images from different visits to discuss treatment progress.

Plastic Surgery →

Dermatologists

Organize photographs by patient and treatment so staff can retrieve earlier images during follow-up appointments.

Dermatology →

Medical spas and aesthetic clinics

Keep treatment photos organized by patient and visit. Compare before-and-after images for laser treatments and other aesthetic procedures during follow-up consultations.

Medical Spa →

Wound care surgeons

Capture and organize wound photographs across visits to track healing progress. Compare images over time and keep each photo connected to the correct patient record for clinical review.

Where does CureCast store patient photos for UAE clinics?

CureCast's UAE deployment uses Microsoft Azure UAE North in Dubai for primary patient photo storage and an active secondary copy in UAE Central, Abu Dhabi. Both locations are in the United Arab Emirates. Confirm the deployment and migration status for your specific account before uploading patient information.

Dubai and UAE data residency are different geographic commitments. The active secondary copy in Abu Dhabi remains within the UAE, but outside Dubai. An active copy does not by itself establish automatic failover or a guaranteed recovery time.

Explore clinical photo management, before-and-after photo software, and workflows for plastic surgeons and dermatologists.

Microsoft lists the geographic locations of Azure regions. Region availability does not independently verify an application's configuration. Review storage, processing, support access and transfers together.

Local storage is one part of your assessment. Review processing, support access, subprocessors, backups and transfers alongside the clinic’s staff controls and consent process.

01

DHA Circular CIR-2026-00000144 and who it covers

Problem 1 · Advertising
CIR-2026-00000144
Image editing, disclaimers, consent, Medical Director approval, personal account liability.
Problem 2 · Data residency
Article 13, Federal Law No. 2 of 2019
Where patient photos may be stored, processed or transferred. Fine of AED 500,000 to 700,000.

What is DHA Circular CIR-2026-00000144 and when did it take effect?

A circular issued by the DHA Health Regulation Sector in August 2026 to private healthcare facilities and professionals in Dubai, enforcing standard code DHA/HRS/HPSD/ST-21, “Standards for Medical Advertisement Content on Social Media”. It replaces the enforcement position under version 1.1 of the same standard.

Obtain from DHA

This analysis draws on law-firm and consultancy summaries. We could not retrieve the primary document from dha.gov.ae, and no summary substitutes for the text you will be held to.

What changed compared with the previous standard?

Version 1.1 was issued 3 August 2022 and took effect 3 October 2022. The 2026 circular tightens enforcement and scope rather than writing a new rulebook: it hardens before-and-after rules, formalises Medical Director authorisation, and extends facility liability to personal and third-party accounts.

Area Standard v1.1
(2022)
Circular CIR-2026-00000144 (2026)
Before-and-after images Permitted with conditions Permitted with conditions, and restricted or prohibited entirely for certain specialised surgical procedures
Editing Restricted No Photoshop or equivalent, no digital filters, no misleading lighting, no altered angles
Disclaimer Required Required, and in the same font size as the rest of the advertisement
Consent Required Written, defining exact purpose, platform distribution and permissible timeframe
Approval Facility responsibility Prior internal review and formal Medical Director authorisation before publication
Personal accounts Less clearly addressed Facility liable for media recorded on its premises wherever it is posted. Personal and professional accounts must be separated
Influencers Less clearly addressed Third-party influencers expressly in scope
Filming patients Restricted Filming or live-streaming under general anaesthesia, during surgery, or in procedure rooms for promotion is prohibited
Audit Not addressed HRS may conduct social media audits. Posts should be archived with edits and formats

Which standard code governs this, and where do I find the official text?

DHA/HRS/HPSD/ST-21, issued by the Health Policy and Standards Department within the DHA Health Regulation Sector. Request the current version and the circular through your facility’s DHA relationship or the Sheryan portal. Do not rely on a summary, including this one, as your compliance record.

Who does it bind?

DHA/HRS/HPSD/ST-21, issued by the Health Policy and Standards Department within the DHA Health Regulation Sector. Request the current version and the circular through your facility’s DHA relationship or the Sheryan portal. Do not rely on a summary, including this one, as your compliance record.

Facilities
Professionals
Marketing staff
Influencers

Does it apply to organic posts and stories, or only paid advertising?

The standard is framed around the promotional character of the content, not whether money changed hands. An organic post promoting a treatment is promotional. Treat organic posts, stories and reels as in scope and route them through the same approval.

Is a clinic landing page a regulated health advertisement?

Health advertising in the UAE is regulated more broadly than social media alone, and the official facility account must display a MOHAP-issued medical advertisement licence number. Whether a given web page falls under ST-21 or the wider advertising permit regime is a question to put to DHA for your facility.

Does it apply to WhatsApp broadcast messages?

Not settled

ST-21 is framed around social media. A WhatsApp broadcast promoting a treatment has the character of a health advertisement, and the prudent position is to apply the same rules. Confirm with DHA rather than assuming it falls outside.

A separate and larger problem applies to WhatsApp regardless. See Is it legal to send patient photos over WhatsApp?

Does it apply to DIFC and Dubai Healthcare City clinics?

No. DIFC and Dubai Healthcare City are excluded from DHA’s standards. If you operate clinics inside and outside these zones, you are subject to more than one framework at once.

  • DHCC: its own regulatory framework and advertisement policy, under the Dubai Healthcare City Authority
  • DIFC: DIFC Law No. 5 of 2020, the DIFC Data Protection Law, supervised by the DIFC Commissioner of Data Protection

What if I am licensed in Abu Dhabi or the northern emirates?

DHA’s standard binds Dubai. Abu Dhabi is regulated by the Department of Health (DoH), the northern emirates by MOHAP, and Dubai Healthcare City by DHCA.

Not verified

We have not verified DoH's before-and-after advertising requirements and will not describe them. Obtain them from DoH rather than assuming they mirror Dubai's.

What is the legal basis for DHA’s authority here?

Executive Council Resolution No. 49 of 2024, regulating health professions and health activities in the Emirate of Dubai, together with Federal Law No. 15 of 2020 on Consumer Protection as amended by Federal Decree-Law No. 5 of 2023.

Status unknown

DHA's standard also references MOHAP Ministerial Decision No. 430 of 2007 on medical advertisement regulation. We could not confirm whether it remains in force or has been superseded.

02

Before-and-after image rules in Dubai

Can I still post before-and-after photos in Dubai?

Yes, for most procedures, under conditions. The image must be of the same patient, taken with the same lens, unedited, with a variability disclaimer in the same font size as the rest of the advertisement, and supported by written patient consent. It is restricted or prohibited entirely for certain specialised surgical procedures.

Highest priority

We cannot list the restricted procedures from the sources available. Confirm this from the circular before you post surgical results.

What are the exact image requirements?

Requirement What it means in practice
Same patient Both frames are the same individual. No composites, no stock, no representative cases
Same lens Before and after on the same optical lens. Switching between a phone's main and telephoto cameras between visits breaks this
No editing software No Photoshop or equivalent. Covers retouching, smoothing, blemish removal and colour grading
No digital filters Including beautification filters applied by default in some phone camera and social apps
No misleading lighting See misleading lighting below
No altered angles The after may not be shot from a more flattering position than the before
Variability disclaimer Same font size as the rest of the advertisement
Written consent Specifying purpose, platform distribution and permissible timeframe

The “same lens” rule is the one clinics fail without knowing. A phone chooses its own lens by zoom and light, and quietly drops from telephoto to the main camera in a dim room. Two photos taken in the same chair three months apart can be on different lenses with nothing on screen to say so.

How CureCast handles this

CureCast records the lens used with every photo captured through the app, along with field of view, zoom factor, device angle and colour temperature. That record lets a practice demonstrate the condition was met rather than assert it.

Can I use any editing software, filters, lighting adjustment or angle changes?

No. The standard prohibits Photoshop or equivalent editing software, digital filters, misleading lighting and altered angles in before-and-after imagery. Cropping to a consistent frame is not editing the subject, but anything that changes how the patient appears is outside what the standard permits.

How CureCast handles this

CureCast does not alter the photo at capture. No background replacement, no smoothing, no filters, no colour correction. The image stored is the image the camera captured.

What counts as misleading lighting in practice?

Any lighting difference between the two frames that makes the result look better than it is. It is usually not deliberate: a before under flat ceiling light and an after near a window will differ in shadow, contrast and skin tone even when nothing was staged.

The defensible position is consistency, not intent. Same place, same light, and hold exposure and colour settings across the series instead of re-metering each shot.

What disclaimer must appear, and how prominent must it be?

A disclaimer that outcomes vary, in the same font size as the rest of the advertisement. The font-size requirement is explicit and the part most often missed: a disclaimer set smaller than the promotional copy does not satisfy the standard.

What is the required wording of the variability disclaimer?

The v1.1 wording, published together with the risks of the procedure:

"There is no guarantee that the result will be the same, as it might vary from one individual to another."
Confirm current wording

This is the 2022 version. Check it against CIR-2026-00000144 before adopting it. We could not obtain the 2026 text.

Are before-and-after images banned outright for any procedures?

Yes. The standard restricts or prohibits before-and-after imagery entirely for certain specialised surgical procedures. The list is in the standard and we will not guess at it. If your practice posts surgical results, obtaining that list is the highest-priority item on this page.

Can I film or live-stream a patient during a procedure?

No. Live-streaming or filming patients under general anaesthesia, during minor or major surgery, or in procedure rooms for promotional purposes is prohibited, regardless of consent and regardless of which account posts it.

Can I post a patient's photo if they were treated at a different facility?

Liability ties to the facility where the media was recorded and to the DHA-licensed professional publishing it. Your consent covers your use, not another facility's patient. Do not post another facility's cases without written consent that names you and your platforms.

Can a visiting practitioner post Dubai patients to their international account?

Visiting practitioners must maintain a separate Dubai account. The facility remains liable for media recorded on its premises wherever it is published, including an international personal account. Agree this in writing before they treat a patient in your clinic.

Written consent, specific to marketing use, defining the exact purpose, the platforms where the image will be distributed, and the permissible timeframe. A signature on a procedure consent form does not cover advertising.

No. Treatment consent covers the procedure and its risks. Marketing consent covers publication, audience and duration. Bundling them means a patient cannot decline one without appearing to decline the other.

ElementWhy it is required
Exact purposeMarketing and promotion, distinguished from clinical record, teaching or peer review
Platform distributionNamed platforms. "Social media" is not a platform
Permissible timeframeA defined period, after which the permission lapses
WithdrawalHow the patient withdraws and what happens when they do

Yes. A verbal agreement, a WhatsApp "yes", or a note in the file is not what the standard asks for.

For the timeframe the consent specifies. No end date does not meet the requirement, and an expired consent no longer supports a live post.

Do I need separate consent for each platform?

One document can name several platforms, but it must name them. Adding a platform later means new consent. Instagram is not TikTok.

What happens if a patient withdraws consent after I have posted?

Remove the content. The permission that made publication lawful no longer exists, and the obligation is immediate. You cannot remove a post reliably if you do not know every place the image was published, which is why the archive matters.

How CureCast handles this

CureCast's marketing consent filter separates consented images from the rest of the patient's file, so marketing works only from approved material and a withdrawal is applied at the source rather than chased across accounts.

04
Section 04 · Governance and liability

Medical Director approval and liability

Do I need Medical Director approval before every social media post?

Yes. No promotional content may be published without prior internal review and formal authorisation from the facility's Medical Director. It is per post, not a standing approval of the marketing function, and it is the item most likely to be tested in an audit.

Who is liable if a doctor posts from their personal account?

The facility. It is liable for all media recorded or filmed on its premises, whether on official channels or personal accounts of doctors, employees or influencers, and whether shot professionally or on a phone. The DHA-licensed professional also carries individual liability.

Am I liable if an influencer films in my clinic and posts from their own account?

Yes. Third-party influencers are expressly in scope, and liability follows the premises. Contract for it in advance:

Approval before posting Defined content Takedown obligation

Do I need to separate personal and professional accounts?

Yes. A single account mixing family photos with treatment promotion is a professional account under the standard, and everything on it is in scope.

Do I have to archive posts?

Posts should be archived, including edits and different formats. An expired story, a replaced reel and an edited caption are all part of what was published. Archive at the point of publication rather than reconstructing later.

Can the DHA audit my social media accounts?

Yes. The Health Regulation Sector may conduct social media audits. An audit examines three things, each easy to produce if created at the time and nearly impossible afterwards:

1
Your archive
2
Your consent records
3
Medical Director authorisations

What are the penalties for non-compliance?

Not stated

We cannot state the sanctions under this standard from the sources available, and will not estimate them. Enforcement sits with the Health Regulation Sector and connects to facility and professional licensing. Obtain the circular for the enforcement provisions.

Do not confuse these with the health data penalties, which are separate and statutory. See Article 24 below.

05
Section 05 · Prohibited content and language

Banned words, titles and pricing

Which specific words are banned in medical advertising in Dubai?

The following words and phrases appear as prohibited in medical advertising in Dubai:

the best safest exclusive the only magic miraculous guaranteed success 100 per cent no side effects immediate results unique one of a kind incomparable unprecedented assured success very limited quantity get money back absolutely certain distinguished famous pioneer
Indicative, not exhaustive

This is the list as reproduced in the summaries available to us. Check your copy against the standard itself, not this page.

Read the list for its logic. Every entry is an absolute claim, a superlative, or commercial urgency. A phrase not on the list that does one of those three things is unlikely to be acceptable. Run it against existing captions, your website and bios too. The archive is in scope.

Can I run flash discounts, bundles or limited-time offers?

No. Inducement pricing, including flash discounts and bundles, is prohibited, because price urgency pushes a medical decision onto a commercial timetable. "Very limited quantity" and "get money back" are banned for the same reason.

Can I say my clinic is better than another clinic?

No. Comparative marketing asserting superiority is prohibited. "The best", "the only", "incomparable" and "unprecedented" are all comparative claims without naming a competitor.

Which professional titles am I not allowed to use?

These imply a scope of practice the DHA licensing framework does not recognise:

  • Cosmetic Specialist
  • Aesthetic Consultant
  • Aesthetician
  • Cosmetologist
  • Anti-Aging Consultant

Who can use the title "Dr" in Dubai medical advertising?

Physicians, dentists and holders of a recognised PhD. Anyone else is misrepresenting qualification.

Do I have to display a licence number on my official account?

Yes, the MOHAP-issued medical advertisement licence number. Anyone can check it in seconds, making it a common first audit finding.

06
Section 06 · Permits and licensing

Advertising permits and Sheryan

Do I need a permit to advertise, and how do I get one?

Advertising permissions are tied to facility licensure and administered through the Sheryan portal. The official account must display the MOHAP-issued medical advertisement licence number.

No fee schedule found

No published fee schedule for DHA advertisement permits could be located. Ask DHA for current fees rather than budgeting from a third-party figure.

What is Sheryan and how does the permit process work?

Sheryan is DHA's licensing and regulatory portal for health professionals and facilities in Dubai. Advertising permissions are administered through it and depend on an active facility licence.

No

Can I advertise while my facility licence is still being approved?

Not during initial approval, and not at all without an active licence. Promoting an opening before the licence is granted is unauthorised advertising.

Yes

Is there a temporary permit for a time-bound campaign?

DHA offers a "Request for Temporary Permit for Campaign" service, available only to facilities with active licences.

07
Section 07 · Data storage and residency

UAE health data residency under Article 13

The section most clinics have not addressed, and the one with a stated financial penalty.

Can a UAE clinic store patient photos on servers outside the UAE?

Not by default. Article 13 of Federal Law No. 2 of 2019 prohibits storing, processing, generating or transferring outside the UAE any health information related to health services provided inside the UAE, except as permitted by a decision of the Health Authority. A clinical photo of a patient treated in Dubai is health data generated in the UAE.

What does Article 13 actually prohibit?

Storing, processing, generating or transferring UAE health data outside the UAE, except as permitted by the Health Authority. The implementing regulation is Cabinet Decision No. 32 of 2020.

Storing
Processing
Generating
Transferring

Note the breadth. Processing outside the UAE is caught even where the data is stored inside it.

What is the penalty for storing UAE health data offshore?

AED 500,000
to AED 700,000

Article 24 of Federal Law No. 2 of 2019 sets a fine of not less than AED 500,000 and not more than AED 700,000. This is a statutory penalty, distinct from any sanction under the advertising standard.

Which exemptions allow health data to leave the UAE?

MOHAP Ministerial Decision No. 51 of 2021 sets the exemption matrix. The exemptions are specific categories with conditions attached, not a general permission. For a cloud application, the relevant route is the online health services exemption, described next.

08
Section 08 · CureCast and Article 13

CureCast UAE hosting and your Article 13 assessment

Check the deployment used by your clinic, including photo storage, recovery, processing and support access.

Does CureCast store UAE patient photos inside the UAE?

CureCast offers a UAE deployment with primary storage in Azure UAE North, Dubai, and an active secondary copy in UAE Central, Abu Dhabi. Confirm the region and migration status for your individual account in writing. Storage location alone does not establish compliance for every processing or support activity.

Which Azure region, and is there any cross-border transfer at any point?

FieldCureCast UAE deployment
Primary regionMicrosoft Azure UAE North, Dubai
Active secondary copyAzure UAE Central, Abu Dhabi. Activation confirmed by CureCast on October 30, 2026; no automatic failover or recovery-time guarantee is stated here.
Sub-processorsRequest the current subprocessor list, processing locations and data processing agreement from CureCast
EncryptionAES-256 at rest, TLS 1.2 or higher in transit
Support accessReview the support-access terms in your data processing agreement and the legal basis for any overseas access
Default or opt-inConfirm provisioning and any migration status for your account
StatusLive in production
One qualification, stated plainly

Confirm development, administration and support-access arrangements in the current data processing agreement. The infrastructure summary does not independently establish where every support activity occurs or who can access patient information. Assess any proposed overseas processing or access against the applicable requirements.

Does UAE storage alone remove all cross-border requirements?

No. Assess storage, processing, access and transfers across the complete service. Article 13 restricts covered health information activities outside the UAE, subject to permitted authority decisions. A local storage region does not by itself establish that every activity stays in-country. Obtain advice on any proposed exception or overseas access.

Who at CureCast can access my patient images, and from where?

Request written confirmation of which CureCast personnel can access patient information, from which locations, and under what approval and logging controls. Confirm these arrangements in your data processing agreement. Clinic permission alone should not be treated as establishing a legal exception for overseas access.

Inside your account, access is per staff member at module and action level, and every view, download, share and export is logged in the audit trail with user, device and timestamp.

Is CureCast DHA compliant?

No software can make a clinic DHA compliant on its own. CureCast is designed to support the parts of a clinical photo workflow that sit within the software: patient photo management, access control, consent-based organization and auditability. Your clinic remains responsible for its policies, consent process, staff training, Medical Director approval and advertising practices.

What CureCast supports

CureCast can support a structured clinical photo workflow, but using the software does not by itself establish compliance with DHA requirements. Clinics should assess their complete workflow against the requirements applicable to their licence and activities.

What are CureCast's sub-processors and where are they located?

The infrastructure summary identifies Microsoft Azure for the UAE deployment. Obtain the current subprocessor list and processing locations from CureCast, including any logging, monitoring and support services. The hosting summary alone does not verify every third-party service or processing location.

Ask for the current list in writing and have it named in your DPA. A list that only exists on a web page is not a contractual commitment.

Is UAE residency the default for UAE clinics, or something I request?

Request written confirmation of the deployment assigned to your clinic account and any outstanding migration before uploading patient information. This page does not establish the provisioning status of every UAE account.

Is UAE-resident storage live today, or planned?

The UAE deployment is described here as live in production. Existing accounts may have a different migration status. Ask CureCast to confirm your account's primary and recovery regions in writing.

Ask every vendor

Ask this question in exactly this form, and ask for a customer reference. "We support UAE hosting" and "we have a clinic running on it" are different statements, and a roadmap commitment is not residency.

Does the UAE PDPL apply to patient photos, or does the Health Data Law govern?

Federal Law No. 2 of 2019 is the sector-specific health data instrument and contains the Article 13 residency restriction. Federal Decree-Law No. 45 of 2021, the PDPL, is the general personal data law. For a clinical photo system in Dubai, Article 13 applies regardless.

Contested

The status of the PDPL Executive Regulations is genuinely contested. One 2026 secondary source names a Cabinet Resolution, uncorroborated. Do not act on any claimed PDPL deadline you cannot verify against a published instrument.

Is it legal to send patient photos over WhatsApp in a Dubai clinic?

This is an Article 13 question first. A photo sent through WhatsApp is transmitted to and processed on infrastructure outside the UAE, and Article 13 covers transferring and processing, not only storage.

  • The image lands in a personal message thread
  • It is typically copied to both sender's and recipient's camera rolls
  • It cannot be revoked, audited or access-controlled

Sharing a link to a controlled system is a different act from sending the image, and it is the pattern a clinic can defend.

Can I store patient photos in Google Drive, Dropbox or iCloud?

Assess the exact service, account type and configuration. Verify storage and processing locations, access controls, audit records, contractual terms and staff offboarding. These capabilities vary by product and plan. A personal cloud account should not be assumed to meet your clinic’s requirements.

What happens to patient photos when a staff member leaves?

Whatever was on their personal device leaves with them. The clinic cannot inventory those copies, cannot recall them, and usually cannot prove they were deleted.

How CureCast handles this

CureCast captures into the patient's file, not the camera roll, and access is per staff member, so revoking one person removes their access to everything at once. A structural answer, not a policy one, because a policy cannot be enforced against a device you no longer hold.

09
Section 09 · Systems and interoperability

NABIDH, ADHICS and information security

Do I need to connect my clinic system to NABIDH?

NABIDH is DHA's health information exchange, and connection is a licensing expectation for DHA-licensed facilities. The obligation sits on the facility and is met through the system of record, normally the EMR. CureCast is not an EMR and is not a NABIDH integration.

  • HL7 and FHIR-conformant integration
  • Emirates ID patient matching
  • Structured clinical document submission
  • Defined consent handling

Whether clinical photos fall within the submission set is a question for DHA and your EMR vendor, worth asking in writing. Malaffi is the Abu Dhabi equivalent, and a group in both emirates connects to each separately. Riayati is the federal layer.

Does ADHICS apply to a Dubai-licensed clinic?

No. ADHICS v2.0, introduced May 2024 and effective August 2024, is mandatory in Abu Dhabi only. It has become a de facto UAE benchmark, and a Dubai group with Abu Dhabi sites will be held to it there, so asking a vendor about it is reasonable even in Dubai.

What should a clinical photo system do to satisfy DHA information-security expectations?

ExpectationWhat to ask a vendor
ResidencyWhich countries and regions hold primary data, secondary copies and backups? Ask for the actual replication configuration and account-specific confirmation
EncryptionAt rest and in transit, with the cipher and TLS version named
Access controlPer individual, at module and action level. Shared logins cannot attribute an action to a person
Audit trailWho viewed, downloaded, shared and exported, with timestamp and device
Backup and restoreWhere backups sit, how long they are kept, and when a restore was last tested
DeletionWhat happens on request, and whether you get written confirmation
CureCast's UAE answers

Primary storage is Azure UAE North, Dubai, with an active secondary copy in Azure UAE Central, Abu Dhabi, confirmed by CureCast on October 30, 2026. The September 12, 2026 infrastructure summary documents AES-256 encryption at rest, HTTPS with minimum TLS 1.2, private file containers and time-limited signed file links. Daily database backups are retained for 30 days and weekly backups for 90 days in Dubai. A September 9, 2026 test restored all 138 database tables successfully. Backup retention is not the same as the clinic’s medical-record retention obligation. This is CureCast’s infrastructure statement, not an independent certification.

10
Section 10 · Retention

Record retention

How long must a Dubai clinic retain patient records and clinical photographs?

Not verified

We could not verify this and will not state a figure. A 25-year period is widely repeated in the UAE market, but we could not confirm it against the Arabic statutory text. Obtain the requirement from DHA for your facility type. Whatever it is, it applies to clinical photos as part of the record.

A retention obligation measured in decades is an argument against holding clinical images anywhere you do not control, including a staff phone or a consumer cloud account.

11
Section 11 · Practical

Compliant workflow, consent form and audit

What is a compliant before-and-after photography workflow, step by step?

DHA requirementWorkflow step that satisfies it
Same patientCapture directly into the patient's file. Never into a camera roll to be filed later
Same lensCapture through a system that records the lens used, so the condition can be demonstrated
No altered anglesTake the follow-up against the earlier photo, with it overlaid on the camera
No misleading lightingSame room, same light, and hold exposure and colour across the series
No editing or filtersNo editing tools. Verify your phone's beautification filters are off
Written consentMarketing consent separate from treatment consent, naming purpose, platforms and timeframe
Consent-limited useMarketing works from a consented album, not the patient library
Disclaimer, same font sizeApplied at publication. A marketing step, not a system step
Medical Director authorisationRecorded before publication, per post
ArchiveCaptured at publication, including edits and formats

The first seven rows are capture and storage. The last three are governance, and no software performs them for you.

A starting point, not legal advice or a guaranteed compliant form. It is assembled from the consent elements described in the applicable standard and should be reviewed for your facility's circumstances before use. Assembled from the consent elements the standard requires: exact purpose, platform distribution, permissible timeframe and written signature. Published in full and free to adapt.

Not reviewed by counsel

Your obligations depend on your licence, specialties and procedures. Have this reviewed before a patient signs it.

CONSENT FOR THE USE OF CLINICAL PHOTOGRAPHS IN MARKETING
Patient name: ______________________
File number: ____________
Facility: ______________________
DHA licence number: ____________
1. What this permission covers. This consent permits the use of photographs of me, taken at this facility, for marketing and promotional purposes. It is separate from my consent to treatment and from the use of photographs in my clinical record.
2. Images covered. ☐ All photographs taken on: ____________ ☐ Only the specific images listed or initialled below: ____________
3. Platforms. I agree to publication on the following named platforms only: ☐ Instagram ☐ Facebook ☐ TikTok ☐ YouTube ☐ Clinic website ☐ Printed materials ☐ Other: ____________. Any platform not named above requires new consent.
4. Timeframe. This permission is valid from ____________ until ____________. After that date the facility will cease publication and remove the images from platforms under its control.
5. How I will appear. ☐ Face may be shown ☐ Face must be obscured ☐ Treated area only. I understand that images will be published unedited, as required by DHA standards, and will not be retouched, filtered or otherwise altered.
6. Withdrawal. I may withdraw this consent at any time, in writing, to ____________. On withdrawal the facility will remove the images from platforms under its control as soon as practicable. I understand that content already shared, screenshotted or reposted by third parties cannot be recalled.
7. No condition on treatment. I understand that my treatment does not depend on giving this consent, and that declining will not affect my care.
Patient signature: ______________
Date: __________
Witness (staff name and role): ______________
Date: __________
Medical Director authorisation for publication: ______________
Date: __________

How do I audit my existing social media archive?

Work backwards from the cheapest checks to the most expensive.

1
The licence number
Is the MOHAP licence number on the official account? One minute, and a common first finding.
2
The banned word list
Search every caption, bio and page for the twenty-one prohibited words. An intern can do it in a day.
3
Titles
Any banned title, and any "Dr" outside physicians, dentists and recognised PhD holders.
4
Pricing posts
Any flash discount, bundle or limited-time offer.
5
Before-and-after posts
Same patient, disclaimer present at the same font size, written consent naming that platform, consent still in its timeframe.
6
Surgical before-and-afters
Checked against the restricted-procedure list from the circular.
7
Personal accounts
Every clinician and staff member who has posted clinic content from a personal account.
8
Influencer content
Anything filmed on your premises and published by someone else.

What do I do if I have already posted images that do not meet the new standard?

Remove first, document second, fix the process third.

1 · Remove
Take down anything failing the checks, without waiting to assess the whole archive.
2 · Document
Record what was removed and when. Remediation you cannot evidence counts for less.
3 · Fix the process
Usually written consent for a named platform, and recorded Medical Director authorisation.
Do not

Do not edit a non-compliant post into compliance and leave the original date. The archive obligation covers edits, and a silently amended post is worse than a removed one.

12
Section 12 · What CureCast does not do

What CureCast does not do

CureCast does not make your practice compliant. Compliance is a property of your whole operation: your policies, training, consent process and governance. Software is one input.

Write your policies
No system supplies your social media policy or consent process.
Obtain consent for you
It records which images are consented. Securing consent is your process.
Approve posts
Medical Director authorisation is a governance step.
Archive your social media
Posts, edits and formats live on the platforms and in your archive.
Apply the disclaimer
Applied at publication, at the required font size.
Connect to NABIDH
CureCast is not an EMR or a health information exchange integration.
Check your captions
The prohibited-word list applies to your copy, not your photo library.
Determine restricted procedures
That list is in the circular. Only DHA can give it to you.
What it does do

Hold the parts that are structural rather than procedural: patient images inside the UAE, captured without editing, with the lens and capture conditions recorded, accessible per individual with an audit trail, and separated into consented and non-consented material.

Is CureCast DHA compliant?

CureCast is not a substitute for DHA compliance, and we do not describe the software as making a clinic “DHA compliant.” DHA compliance applies to the clinic's complete operation, including its health-information management, security controls, consent processes, staff practices and applicable regulatory obligations.

What CureCast supports

CureCast is designed to support the secure management of clinical photographs and patient records through controlled staff access, auditability, encrypted storage and structured clinical photo workflows. DHA's Health Information Assets Management Policy expressly covers health information stored in cloud-based systems, including the systems and infrastructure used by healthcare entities.

Whether a particular clinic meets its DHA obligations depends on how the clinic configures and uses its systems, as well as its policies, consent process, staff training and other regulatory requirements. CureCast can support that workflow; it does not replace the clinic's compliance responsibilities.

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Section 13 · Sources

Sources

Primary instruments. Obtain current texts from the issuing authority rather than relying on this page.

  1. DHA Circular CIR-2026-00000144, August 2026, enforcing DHA/HRS/HPSD/ST-21, Standards for Medical Advertisement Content on Social Media. Predecessor v1.1 issued 3 August 2022, effective 3 October 2022. Dubai Health Authority
  2. Executive Council Resolution No. 49 of 2024, Regulating Health Professions and Health Activities in the Emirate of Dubai
  3. Federal Law No. 15 of 2020 on Consumer Protection, as amended by Federal Decree-Law No. 5 of 2023
  4. Federal Law No. 2 of 2019 on the Use of ICT in Health Fields. Article 4 (confidentiality), Article 13 (data residency), Article 16 (purpose limitation), Article 24 (penalties). Official health data law
  5. Cabinet Decision No. 32 of 2020, implementing regulation to Federal Law No. 2 of 2019
  6. MOHAP Ministerial Decision No. 51 of 2021, exemptions to the health data residency restriction. Ministry of Health and Prevention
  7. Federal Decree-Law No. 45 of 2021 (UAE PDPL). Executive Regulations status unconfirmed
  8. DIFC Law No. 5 of 2020, DIFC Data Protection Law, effective 1 July 2020, enforceable 1 October 2020. DIFC Commissioner of Data Protection
  9. ADHICS v2.0, introduced May 2024, effective August 2024. Department of Health Abu Dhabi
  10. Sheryan, DHA licensing portal. Sheryan

What we could not verify

Stated plainly, because a knowledge page that hides its gaps is not one.

  • The text of CIR-2026-00000144. Analysis draws on law-firm and consultancy summaries
  • Which surgical procedures are restricted. Not in any source available to us
  • The 25-year retention period. Unverified against statutory text
  • UAE PDPL Executive Regulations. Contested, and we will not assert either way
  • MOHAP Ministerial Decision No. 430 of 2007. Whether it remains in force
  • DoH Abu Dhabi before-and-after requirements. Not retrieved, not assumed to mirror Dubai's
  • DHA advertisement permit fees. No published schedule located

Written by Vishal Parikh, Founder, CureCast. Content updated 30 October 2026. For DHA-licensed practices in the Emirate of Dubai. Not legal advice, and not reviewed by UAE counsel. These rules carry personal liability for the licensed professional as well as the facility. Have counsel review before relying on anything here, and obtain CIR-2026-00000144 from DHA rather than relying on any summary, including this one.