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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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to access electronically stored data backups or copies during the

retention period

- Routine backup copies should be stored in a remote location

(physically separated) in the event of disasters.

- Back-up data should be readable for all the period of the defined

regulatory retention period, even if a new version of the software

has been updated or substituted for one with better performance.

- Systems should allow backup and restoration of all data, including

meta-data and audit trails.

Potential risk of not meeting expectations/items to be checked

Check that data storage, back-up and archival systems are

designed to capture all data and relevant metadata. There should

be documented evidence that these systems have been validated

and verified.

The extent of metadata captured should be based on risk

management principles, and users should ensure that all metadata

critical in the reconstruction of activities or processes are captured.

Check that data associated with superseded or upgraded systems

is managed appropriately and is accessible.

2. Expectation

The record retention procedures should include provisions for retaining

the metadata. This allows for future queries or investigations to

reconstruct the activities that occurred related to a batch.

3. Expectation

Data should be backed-up periodically and archived in accordance with

written procedures. Archive copies should be physically (or virtually, where

relevant) secured in a separate and remote location from where back up

and original data are stored.

The data should be accessible and readable and its integrity maintained for

all the period of archiving.

There should be in place a procedure for restoring archived data in case an

investigation is needed. The procedure in place for restoring archived data

should be regularly tested.

If a facility is needed for the archiving process then specific environmental

controls and only authorised personnel access should be implemented in

order to ensure the protection of records from deliberate or inadvertent

alteration or loss. When a system in the facility has to be retired because

problems with long term access to data are envisaged, procedures should

assure the continued readability of the data archived. For example, it could

be established to transfer the data to another system.

Potential risk of not meeting expectations/items to be checked

There is a risk with archived data that access and readability of the

data may be lost due to software application updates or superseded

equipment. Verify that the company has access to archived data,

PI 041-1 51 of 63 1 July 2021

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