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Data integrity PIC S

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

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9.5 System security for computerised systems

Item: System security

1. Expectation

User access controls shall be configured and enforced to prohibit

unauthorised access to, changes to and deletion of data. The extent of

security controls is dependent on the criticality of the computerised system.

For example:

- Individual Login IDs and passwords should be set up and assigned

for all staff needing to access and utilise the specific electronic

system. Shared login credentials do not allow for traceability to the

individual who performed the activity. For this reason, shared

passwords, even for reasons of financial savings, should be

prohibited. Login parameters should be verified during validation of

the electronic system to ensure that login profiles, configuration and

password format are clearly defined and function as intended.

- Input of data and changes to computerised records should be made

only by authorised personnel. Companies should maintain a list of

authorised individuals and their access privileges for each electronic

system in use.

- Appropriate controls should be in place regarding the format and

use of passwords, to ensure that systems are effectively secured.

- Upon initially having been granted system access, a system should

allow the user to create a new password, following the normal

password rules.

- Systems should support different user access roles (levels) and

assignment of a role should follow the least-privilege rule, i.e.

assigning the minimum necessary access level for any job function.

As a minimum, simple systems should have normal and admin

users, but complex systems will typically requires more levels of

users (e.g. a hierarchy) to effectively support access control.

- Granting of administrator access rights to computerised systems

and infrastructure used to run GMP/GDP critical applications should

be strictly controlled. Administrator access rights should not be

given to normal users on the system (i.e. segregation of duties).

- Normal users should not have access to critical aspects of the

computerised system, e.g. system clocks, file deletion functions,

etc.

- Systems should be able to generate a list of users with actual

access to the system, including user identification and roles. User

lists should include the names or unique identifiers that permit

identification of specific individuals. The list should be used during

periodic user reviews.

- Systems should be able to generate a list of successful and

unsuccessful login attempts, including:

o User identification

o User access role

o Date and time of the attempted login, either in local time or

traceable to local time

o Session length, in the case of successful logins

PI 041-1 40 of 63 1 July 2021

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