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Data integrity PIC S

good practices for data management and integrity in regulatory GMP/GDP environments

good practices for data management and integrity in regulatory GMP/GDP environments

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Remote access to unsupported systems should be carefully evaluated due

to inherent vulnerability risks.

Potential risk of not meeting expectations/items to be checked

Verify that system updates are performed in a controlled and timely

manner. Older systems should be reviewed critically to determine

whether appropriate data integrity controls are integrated, or,

(where integrated controls are not possible) that appropriate

administrative controls have been implemented and are effective.

9.4 Data Transfer

Item: Data transfer and migration

1. Expectation

Interfaces should be assessed and addressed during validation to ensure

the correct and complete transfer of data.

Interfaces should include appropriate built-in checks for the correct and

secure entry and processing of data, in order to minimise data integrity

risks. Verification methods may include the use of:

o Secure transfer

o Encryption

o Checksums

Where applicable, interfaces between systems should be designed and

qualified to include an automated transfer of GMP/GDP data.

Potential risk of not meeting expectations/items to be checked

Interfaces between computerised systems present a risk whereby

data may be inadvertently lost, amended or transcribed incorrectly

during the transfer process.

Ensure data is transferred directly to the secure location/database

and not simply copied from the local drive (where it may have the

potential to be altered).

Temporary data storage on local computerised systems (e.g.

instrument computer) before transfer to final storage or data

processing location creates an opportunity for data to be deleted or

manipulated. This is a particular risk in the case of ‘standalone’

(non-networked) systems. Ensure the environment that initially

stores the data has appropriate DI controls in place.

Well designed and qualified automated data transfer is much more

reliable than any manual data transfer conducted by humans.

2. Expectation

Where system software (including operating system) is installed or

updated, the user should ensure that existing and archived data can be

PI 041-1 38 of 63 1 July 2021

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