Security and procurement · 20 August 2026 · Pathways

What data sovereignty actually requires

Data sovereignty means patient information stays within Australian jurisdiction across its whole lifecycle — storage, processing, backup and any third-party service it passes through. Claiming an Australian region for the primary database is the easy part. The paths that matter are backups, subprocessors, support access, and, for AI systems, what is sent to a model provider.

Every health-tech vendor selling into Australia says their data stays in Australia. Most of them mean it. The claim is still worth interrogating, because “hosted in Australia” describes where a database sits, and sovereignty is a property of every path the data can take.

For a procurement officer, the difference between those two things is the difference between a statement and an assurance.

The paths that get overlooked

Primary storage is the part everyone gets right, because it is the part everyone asks about. Underneath it sit four routes that are easier to miss.

Backups and disaster recovery. A primary region in Sydney with replication to a secondary region elsewhere is not sovereign. This is easy to configure accidentally, because cross-region replication is a sensible default for durability and is often enabled without a specific decision.

Processing, not just storage. Data at rest in Sydney can still be processed somewhere else — a job queue, a search index, an analytics pipeline. Storage location and processing location are separate facts and need separate answers.

Subprocessors. Error monitoring, logging, session replay, email delivery, customer support tooling. Each is a service the data passes through, and each has its own region. A vendor whose own infrastructure is entirely Australian can still be exporting patient data through a logging provider.

Support access. Where an engineer sits when they open a production console is a jurisdictional question, whatever the region the data is stored in.

None of these is exotic and none implies bad faith. They are the ordinary consequences of assembling a modern application from services, and they are why “where is it hosted” is a weaker question than it sounds.

The path specific to AI systems

Then there is the one that did not exist a few years ago and now dominates the assessment: what is sent to a model provider.

If a system uses a large language model to conduct an interview, read a medication photograph, or summarise a history, that content leaves the application. Where it goes, what is retained, and whether it is used for training are three separate questions, and a vendor can answer one well while being vague on the others.

There are two guarantees worth insisting on, because they fail independently:

Identity. Is personally identifying information sent to the model provider at all? De-identifying the content before it leaves means the provider never receives a named patient record, which changes the exposure from a jurisdictional problem into a much narrower one.

Training. Is the content used to train models? This is a separate commitment, and it is the one where contractual terms matter more than architecture — because unlike de-identification, you cannot verify it from the outside.

The architectural answer that removes the question

For the parts of a clinical system that matter most, there is a stronger position available than a good answer about model providers: not involving one.

Safety-critical screening — an unwithheld SGLT2 inhibitor, poor glycaemic control, an untreated sleep apnoea screen — can be implemented as deterministic, versioned rules operating on structured findings. Rules of that kind do not call a model. They execute locally, in the same jurisdiction as the data, and they produce the same output every time.

That is worth stating plainly because it changes what the sovereignty question applies to. Models are used where the input is unstructured and brittle rules genuinely fail: conducting a conversational interview, reading handwriting on a pharmacy label, turning narrative into structured findings. Their output is an input to the rules, never a substitute for them.

So the surface area exposed to a model provider is narrower than “the clinical system”, and the part of the system a governance committee is most concerned about is the part that never leaves.

Questions worth asking any vendor

Sovereignty is best assessed by asking about paths rather than about location:

  • In which region is patient data stored, and where do backups and any replicas live?
  • Where is it processed, as distinct from stored?
  • Which subprocessors touch it, and in which jurisdictions do they operate?
  • From where can your staff access production data, and is that access logged?
  • Is any personally identifying information sent to a model provider?
  • Is patient content used to train models, by you or by anyone you use?
  • Which parts of the clinical logic involve a model at all?

A vendor who has thought about this will answer each one specifically. One who has not will re-answer the first question several times.

Where Pathways sits

For completeness, the same answers for Pathways: all patient data is stored in AWS Sydney (ap-southeast-2) and is not transferred outside Australia in storage, processing or backup. No personally identifying information is sent to model providers, and patient information is not used to train models. Extraction and reasoning operate on de-identified clinical content. The safety-critical screening rules are deterministic and versioned, so they do not involve a model provider at all, and every output records the rule version that produced it.

The full control set, and the governance pack for procurement review, are on the security page.

FAQ

Related questions

Where is Pathways patient data stored?

All Pathways patient data is stored in AWS Sydney (ap-southeast-2). Patient information is not transferred outside Australia in storage, processing or backup. Data is encrypted in transit using TLS 1.2 or above and at rest with keys managed in AWS KMS.

Data sovereignty is a procurement gate for most Australian health services, so it is worth being precise about the boundary. The Australian region covers the full lifecycle: primary storage, processing during an assessment, and backups. There is no cross-region replication of patient information.

Does Pathways send patient data to AI model providers?

No. No personally identifying information is sent to model providers. Extraction and reasoning operate on de-identified clinical content, and patient information is never used to train models. The safety-critical screening rules are deterministic code rather than model output, so they do not involve a model provider at all.

This is two separate guarantees, and they are worth separating because they fail in different ways.

The first is about identity: the content that reaches a model provider is de-identified, so a model provider never receives a named patient record. The second is about training: patient information is not used to train models, by anyone, at any point.

Underneath both sits a design decision that removes the question for the parts that matter most. The rules that protect patients — the SGLT2 withholding check, the glycaemic control threshold, the OSA screen — are deterministic, versioned code. They are not a model output that happens to be reliable; they fire every time their conditions are met and cannot be argued out of it.

Do patients know they are speaking to an AI?

Yes. The interview opens by identifying Pathways as an automated assistant working on behalf of your practice or hospital, and tells the patient that a clinician will review everything discussed. Patients can ask to speak to a person at any point rather than continue with the assessment.

Disclosure is not a compliance box here, it is what makes the answers usable. A patient who thinks they are filling in a form gives form-shaped answers; a patient who understands they are being interviewed, and that a clinician will read it, tends to volunteer the thing that matters — the stent nobody recorded, the sleep study that was never followed up.

Telling them a clinician reviews the result is also simply accurate. Pathways issues no orders and clears no patients; the summary is a draft until someone qualified signs it.

Does Pathways need to integrate with our PMS or EMR?

No. Pathways runs standalone from day one. The SMS-driven workflow needs no patient management or EMR integration to start, so a service can screen its next elective list without an IT project, an interface engine, or a change window. Integration is available later but is not a precondition.

This is usually the difference between a deployment measured in days and one measured in quarters. Most of the value — screening every booked patient early enough to act — does not depend on a bidirectional interface, so requiring one up front only delays the point at which the first cancellation is prevented.

When you do want it, integration is HL7 or FHIR against your patient administration and EMR systems: automated list ingestion from theatre scheduling in one direction, and write-back of the signed pre-operative summary to the patient record in the other. That is an Enterprise capability, available on Business, and it is scoped after the standalone deployment is running rather than before it.

Is Pathways a medical device, and who is responsible for clinical decisions?

Pathways is clinical decision support intended for use by qualified clinicians within Australian clinical governance frameworks. It is clinician-in-the-loop by design — it issues no automated orders, and every recommendation is reviewable and auditable. The treating clinician remains solely responsible for all clinical decisions.

The positioning is deliberate and is reflected in the architecture rather than only in the terms of service. Pathways produces risk flags with severity tiers, the evidence that triggered them, a guideline reference and a recommended action. It does not place orders, it does not clear patients, and it does not route anyone to theatre on its own authority.

How does Pathways generate its risk flags?

Pathways screens each case with deterministic, versioned rules referenced to perioperative guidelines. Every flag carries a severity tier, the clinical rationale, the triggering evidence, the guideline reference and a recommended action, plus the rule version that produced it. The same inputs always produce the same flags, months later.

Screening covers the domains that drive perioperative outcomes: unstable cardiac symptoms, marked hypertension, diabetes control and SGLT2 management, obstructive sleep apnoea, frailty, malnutrition, functional capacity, smoking and discharge support.

Pathways also states what it does not know. Missing investigations and unconfirmed timings are listed explicitly on every profile, and extraction confidence is shown rather than hidden — a profile that is 86% confident about a patient-reported HbA1c says so.

Can we audit why a patient was cleared or flagged?

Yes. Pathways keeps org-wide and per-patient audit logs with full workflow tracing on every risk analysis — the inputs used, the rule version that fired, the output produced, and the human who reviewed it, all timestamped. Logs are exportable for governance committees, M&M review and accreditation.

Because the safety-critical rules are deterministic and versioned, an audit is reproducible rather than merely archived: re-running a case against the rule version recorded at the time produces the same flags. That is the property that lets a decision made in March be examined in September without argument about whether the system “would have said something different”.

Who inside our organisation can see patient data?

Access is role-based. Booking staff, nurses and anaesthetists each see what their role requires and nothing more, and every view and action is written to the audit log. Access is scoped to your organisation — Pathways staff do not browse patient records, and there is no shared or cross-organisation view.

Two questions usually sit behind this one.

Internally, the answer is role-based access plus a complete audit trail. Who saw what, and when, is a recorded fact rather than an assumption, which is what allows the access model to be reviewed rather than merely asserted.

Externally, patient data does not leave your organisation’s scope. It is stored in AWS Sydney, it is not pooled across customers, and the content that reaches model providers is de-identified.

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