InterviewKata
Software architecture · Case study 12 · Reliability and compliance

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.

Invented companyNightRead is a realistic composite. The HIPAA rules, the HHS cloud guidance, India's DPDP Act and the cloud regions it relies on are real and linked under Sources. This is an architecture case, not legal advice.

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

DriverSource
Protect US patients' health informationHIPAA. 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 IndiaIndia'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 recoveryHIPAA Security Rule contingency plan: a data backup plan and a disaster recovery plan are required; testing them is "addressable"
Breach responseHIPAA: notify affected individuals without unreasonable delay and no later than 60 days after discovery. Know exactly whose data is where
Overnight reads continueUS hospitals' service levels: back within 1 hour (RTO), at most 5 minutes of lost work (RPO)

3. The options

OptionGoodBad
One global platform in the USSimplestBreaks the Indian clinics' contracts; Indian clinics see high latency
Replicate scans to India for the radiologistsFast local readingUS patient data stored in India: breaks the hospitals' contracts; twice the copies to secure and to notify about
Two country cells; radiologists read remotelyEach patient's data stays in its country; reads stream across the border as images, not filesTwo 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

9. Your turn

  1. 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).
  2. Draw the trust boundary (10 min). Where does data cross a border or an organisation? What crosses: files, rendered views, aggregates?
  3. Pick the standby (5 min). For your most important service, where would the recovery site be, and does it satisfy the same rules?
Say it in the interview
  • "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?

HHS guidance allows a cloud provider to store ePHI outside the US under a BAA; the US-only rule is contractual.

Where must the Indian cell's disaster recovery site be?

The standby holds the same data, so it must satisfy the same residency requirement.

How does an Indian radiologist read a US scan without moving the data?

Access travels to the data: a server-side viewer, no downloads, every view logged.

11. Sources and further reading

SourceWhy
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 RegionsTwo regions in India (Mumbai, Hyderabad) and several in the US.