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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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and that they maintain access to the necessary software to enable

review of the archived data.

Where external or third party facilities are utilised for the archiving

of data, these service providers should be subject to assessment,

and all responsibilities recorded in a quality technical agreement.

Check agreements and assessment records to verify that due

consideration has been given to ensuring the integrity of archived

records.

4. Expectation

It should be possible to print out a legible and meaningful record of all the

data generated by a computerised system (including metadata).

If a change is performed to records, it should be possible to also print out

the change of the record, indicating when and how the original data was

changed.

Potential risk of not meeting expectations/items to be checked

Check validation documentation for systems to ensure that systems

have been validated for the generation of legible and complete

records.

Samples of print-outs may be verified.

5. Expectation

Procedures should be in place that describe the process for the disposal of

electronically stored data. These procedures should provide guidance for

the assessment of data and allocation of retention periods, and describe

the disposal of data that is no longer required.

Potential risk of not meeting expectations/items to be checked

Check that the procedures clearly stipulate the conditions for the

disposal of data, and that care is taken to avoid the inadvertent

disposal of required data during its lifecycle.

9.10 Management of Hybrid Systems

Item:

Management of Hybrid Systems

1. Hybrid systems require specific and additional controls in reflection of their

complexity and potential increased vulnerability to manipulation of data. For

this reason, the use of hybrid systems is discouraged and such systems

should be replaced whenever possible.

Each element of the hybrid system should be qualified and controlled in

accordance with the guidance relating to manual and computerised

systems as specified above.

PI 041-1 52 of 63 1 July 2021

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