Health data across India and the US
A teleradiology company has radiologists in India reading scans overnight for US hospitals, and a growing business with Indian clinics. US hospitals want their patients' data in the US; Indian clinics want theirs in India; the radiologists in Bengaluru must read US scans as if they were local; and when a region fails at 3 a.m., reads must continue within an hour. The architecture that satisfies all four is built on one principle: the data stays where it belongs, and access travels to it.
1. The situation
NightRead provides overnight radiology reads: US hospitals upload CT and MRI scans, and radiologists in India report on them during the US night. It also serves 150 Indian clinics with daytime reads for Indian patients. 60 engineers; scans are large (a CT study can be hundreds of megabytes) and arrive around the clock.
2. What mattered
| Driver | Source |
|---|---|
| Protect US patients' health information | HIPAA. NightRead handles protected health information for hospitals, so it signs business associate agreements, and needs one with its cloud provider. HHS guidance says HIPAA allows storing ePHI outside the US with a BAA; the US-only requirement comes from the hospitals' contracts |
| Indian patients' data in India | India's DPDP Act (2023) allows transfer abroad except to countries the government restricts; the India-only requirement comes from the clinics' contracts |
| Backups and disaster recovery | HIPAA Security Rule contingency plan: a data backup plan and a disaster recovery plan are required; testing them is "addressable" |
| Breach response | HIPAA: notify affected individuals without unreasonable delay and no later than 60 days after discovery. Know exactly whose data is where |
| Overnight reads continue | US hospitals' service levels: back within 1 hour (RTO), at most 5 minutes of lost work (RPO) |
3. The options
| Option | Good | Bad |
|---|---|---|
| One global platform in the US | Simplest | Breaks the Indian clinics' contracts; Indian clinics see high latency |
| Replicate scans to India for the radiologists | Fast local reading | US patient data stored in India: breaks the hospitals' contracts; twice the copies to secure and to notify about |
| Two country cells; radiologists read remotely | Each patient's data stays in its country; reads stream across the border as images, not files | Two platforms to operate; the viewer must be fast across 12,000 km |
4. The decision
ADR-009: Country cells, remote reading, in-country disaster recovery
Decision:
- US cell (us-east-1, warm standby in us-west-2) holds all US patient data:
scans, reports, audit logs, backups, encryption keys.
- India cell (Mumbai ap-south-1, warm standby in Hyderabad ap-south-2) holds
all Indian patient data, the same way.
- A small global directory holds only routing data: tenant -> cell, and user
identities via single sign-on. No patient data.
- Radiologists in India read US studies in a server-side rendered viewer
running in the US cell: pixels stream to the browser; no download,
no local cache, watermark with reader ID, every view in the US audit log.
- Backups and replicas never leave the cell's country (fitness function).
- Restore tests quarterly in each cell; DR exercise twice a year.
Consequences:
+ Each data type has one country, which contracts, audits and breach
notification can rely on
+ Losing a region in one country doesn't affect the other cell
- Two cells to run and upgrade; the viewer needs a fast, steady link
- Analytics across both countries only from aggregated, de-identified data
5. How it works
One night: a scan arrives from a hospital in Ohio, a radiologist in Bengaluru reads it, and then us-east-1 fails.
6. Choose the recovery strategy
Pick a strategy for the reading workflow (target: back within 1 hour, at most 5 minutes of lost work) and where the recovery site is. Costs are relative to running one region alone, and illustrative.
Typical recovery for each strategy, from the AWS disaster recovery whitepaper's four options (see the DR plan template); NightRead's own numbers would come from its exercises. Relative costs are rough illustrations.
7. How it played out
In the first DR exercise, failing the US cell over to us-west-2 took 38 minutes, inside the one-hour target, but the viewer's session store hadn't been replicated, so every radiologist had to log in again mid-read. The fix went into the runbook and the next exercise took 22 minutes. A hospital's security questionnaire asked where scans, reports, backups and logs live and who can see them; the answer was one table from the ADR. When an Indian clinic asked to use the reporting dashboard across all its sites in both countries, the answer was the aggregated, de-identified feed, not a copy of records.
8. Lessons
- Find where each requirement really comes from. HIPAA doesn't require US storage; the hospitals' contracts do. That matters when a contract is renegotiated or a new customer has different terms (Module 04).
- Data stays, access travels. Streaming rendered images across the border meets residency where copying files would not, at the cost of latency (threat modelling: the viewer is the trust boundary).
- Disaster recovery has a country too. The standby region must satisfy the same residency rules as the primary: two regions in one country (C10, C11).
- Cells limit the blast radius of everything. An outage, a breach or a bad deploy in one country stays there (C01 used the same idea).
- Exercise the failover. The first exercise found a session store nobody had listed. Plans describe; exercises discover.
9. Your turn
- Map the data (15 min). For a system you know: each kind of personal data, the country it must stay in, and the source of that rule (a law, a contract, a policy).
- Draw the trust boundary (10 min). Where does data cross a border or an organisation? What crosses: files, rendered views, aggregates?
- Pick the standby (5 min). For your most important service, where would the recovery site be, and does it satisfy the same rules?
- "Users and staff are in two countries with different data rules. How would you design it?" One cell per country, holding that country's personal data, backups and keys, with disaster recovery in a second region of the same country. Staff in the other country reach data through rendered, audited sessions, and cross-country reporting uses de-identified aggregates.
10. Check yourself
Does HIPAA itself require NightRead to keep US patient data in the US?
Where must the Indian cell's disaster recovery site be?
How does an Indian radiologist read a US scan without moving the data?
11. Sources and further reading
| Source | Why |
|---|---|
| Guidance on HIPAA and cloud computing (HHS) | BAAs with cloud providers; storage outside the US. |
| 45 CFR 164.308 (HIPAA Security Rule) | The contingency plan: data backup, disaster recovery, emergency mode, testing. |
| 45 CFR 164.404 (Breach Notification Rule) | Notification no later than 60 calendar days after discovery. |
| Digital Personal Data Protection Act, 2023 (PRS Legislative Research summary) | Consent, rights, and transfer outside India except to restricted countries. |
| AWS Regions | Two regions in India (Mumbai, Hyderabad) and several in the US. |