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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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- Data should be entered in a specified format that is controlled by the

software, validation activities should verify that invalid data formats

are not accepted by the system.

- All manual data entries of critical data should be verified, either by

a second operator, or by a validated computerised means.

- Changes to entries should be captured in the audit trail and

reviewed by an appropriately authorised and independent person.

For automated data capture: (refer also to table 9.3)

- The interface between the originating system, data acquisition and

recording systems should be validated to ensure the accuracy of

data.

- Data captured by the system should be saved into memory in a

format that is not vulnerable to manipulation, loss or change.

- The system software should incorporate validated checks to ensure

the completeness of data acquired, as well as any relevant

metadata associated with the data.

Potential risk of not meeting expectations/items to be checked

Ensure that manual entries of critical data made into computerised

systems are subject to an appropriate secondary check.

Validation records should be reviewed for systems using automated

data capture to ensure that data verification and integrity measures

are implemented and effective, e.g. verify whether an auto save

function was validated and, therefore, users have no ability to

disable it and potentially generate unreported data.

2. Expectation

Any necessary changes to data should be authorised and controlled in

accordance with approved procedures.

For example, manual integrations and reprocessing of laboratory results

should be performed in an approved and controlled manner. The firm’s

quality unit should establish measures to ensure that changes to data are

performed only when necessary and by designated individuals. Original

(unchanged) data should be retained in its original context.

Any and all changes and modifications to raw data should be fully

documented and should be reviewed and approved by at least one

appropriately trained and qualified individual.

Potential risk of not meeting expectations/items to be checked

Verify that appropriate procedures exist to control any

amendments or re-processing of data. Evidence should

demonstrate an appropriate process of formal approval for the

proposed change, controlled/restricted/defined changes and

formal review of the changes made.

PI 041-1 48 of 63 1 July 2021

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