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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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- in the case of changes or modifications to data, the name of any

person authorising the change.

The audit trail should allow for reconstruction of the course of events

relating to the creation, modification, or deletion of an electronic record.

The system should be able to print and provide an electronic copy of the

audit trail, and whether viewing in the system online or in a hardcopy, the

audit trail should be available in a meaningful format.

If possible, the audit trail should retain the dynamic functionalities found in

the computerised system, (e.g. search functionality and ability to export

data such as to a spreadsheet).

Note: An audit trail should not be confused with a change control system

where changes may needed to appropriately controlled and approved

under a PQS.

Potential risk of not meeting expectations/items to be checked

Verify the format of audit trails to ensure that all critical and relevant

information is captured.

The audit trail should include all previous values and record

changes should not overwrite or obscure previously recorded

information.

Audit trail entries should be recorded in true time and reflect the

actual time of activities. Systems recording the same time for a

number of sequential interactions, or which only make an entry in

the audit trail, once all interactions have been completed, may not

be in compliance with expectations to data integrity, particularly

where each discrete interaction or sequence is critical, e.g. for the

electronic recording of addition of 4 raw materials to a mixing vessel.

If the order of addition is a critical process parameter (CPP), then

each addition should be recorded individually, with time stamps. If

the order of addition is not a CPP then the addition of all 4 materials

could be recorded as a single timestamped activity.

9.7 Data capture/entry for computerised systems

Item:

Data capture/entry

1. Expectation

Systems should be designed for the correct capture of data whether

acquired through manual or automated means.

For manual entry:

- The entry of critical data should only be made by authorised

individuals and the system should record details of the entry, the

individual making the entry and when the entry was made.

PI 041-1 47 of 63 1 July 2021

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