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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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read by the new software. Where necessary this may require conversion of

existing archived data to the new format.

Where conversion to the new data format of the new software is not

possible, the old software should be maintained, e.g. installed in one

computer or other technical solution, and also available as a backup media

in order to have the opportunity to read the archived data in case of an

investigation.

Potential risk of not meeting expectations/items to be checked

It is important that data is readable in its original form throughout the

data lifecycle, and therefore users should maintain the readability of

data, which may require maintaining access to superseded

software.

The migration of data from one system to another should be

performed in a controlled manner, in accordance with documented

protocols, and should include appropriate verification of the

complete migration of data.

3. Expectation

When legacy systems software can no longer be supported, consideration

should be given to maintaining the software for data accessibility purposes

(for as long possible depending upon the specific retention requirements).

This may be achieved by maintaining software in a virtual environment.

Migration to an alternative file format that retains as much as possible of

the ‘true copy’ attributes of the data may be necessary with increasing age

of the legacy data.

Where migration with full original data functionality is not technically

possible, options should be assessed based on risk and the importance of

the data over time. The migration file format should be selected considering

the balance of risk between long-term accessibility versus the possibility of

reduced dynamic data functionality (e.g. data interrogation, trending, reprocessing,

etc.) The risk assessment should also review the vulnerability

of the system to inadvertent or unauthorised changes to critical

configuration settings or manipulation of data. All controls to mitigate risk

should be documented and their effectiveness verified. It is recognised that

the need to maintain accessibility may require migration to a file format that

loses some attributes and/or dynamic data functionality.

Potential risk of not meeting expectations/items to be checked

When the software is maintained in a virtual environment, check that

appropriate measures to control the software (e.g. validation status,

access control by authorised persons, etc.) are in place. All controls

should be documented and their effectiveness verified.

PI 041-1 39 of 63 1 July 2021

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