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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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4. Electronic signatures used in the place of handwritten signatures should

have appropriate controls to ensure their authenticity and traceability to the

specific person who electronically signed the record(s).

Electronic signatures should be permanently linked to their respective

record, i.e. if a later change is made to a signed record; the record should

indicate the amendment and appear as unsigned.

Where used, electronic signature functionality should automatically log the

date and time when a signature was applied.

The use of advanced forms of electronic signatures is becoming more

common (e.g. the use of biometrics is becoming more prevalent by firms).

The use of advanced forms of electronic signatures should be encouraged.

Potential risk of not meeting expectations/items to be checked

Check that electronic signatures are appropriately validated, their

issue to staff is controlled and that at all times, electronic signatures

are readily attributable to an individual.

Any changes to data after an electronic signature has been

assigned should invalidate the signature until the data has been

reviewed again and re-signed.

5. Restrictions on use of USB devices

For reasons of system security, computerised systems should be

configured to prevent vulnerabilities from the use of USB memory sticks

and storage devices on computer clients and servers hosting GMP/GDP

critical data. If necessary, ports should only be opened for approved

purposes and all USB devices should be properly scanned before use.

The use of private USB devices (flash drives, cameras, smartphones,

keyboards, etc.) on company computer clients and servers hosting

GMP/GDP data, or the use of company USB devices on private computers,

should be controlled in order to prevent security breaches.

Potential risk of not meeting expectations/items to be checked

This is especially important where operating system vulnerabilities

are known that allow USB devices to trick the computer, by

pretending to be another external device, e.g. keyboard, and can

contain and start executable code.

Controls should be in place to restrict the use of such devices to

authorised users and measures to screen USB devices before use

should be in place.

PI 041-1 44 of 63 1 July 2021

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