Analysis of the LTDP Requirements of ALCOA
This chapter will cover:
- Importance of ALCOA
- Requirements for LTDP
- ALCOA reminder
A set of requirements for a system used for long-term Data Integrity is provided below. These requirements have been derived from the ALCOA+ principles and an analysis of the regulatory guidelines for Data Integrity. Each ALCOA+ principle below includes the definition of the principle taken from the latest draft EMA guidelines[36]. The guidelines for Data Integrity from the FDA, EMA, MHRA and WHO emphasise the importance of a range of areas when achieving ALCOA compliance, including the use of audit trails, digital signatures, maintaining Data Integrity during transfers and migrations, the creation of true copies from originals, the handling of static and dynamic data, and other related areas. These requirements and guidelines are incorporated into the analysis below.
The requirements below focus on what’s needed to achieve long-term Data Integrity. They cover the archiving and long-term retention stages of the data lifecycle. Additional requirements will need to be met when the data is ‘live’.
Various systems can be considered when looking for a solution to the requirements. These include:
- The system originally used to create, process, manage, and retain data when it was live, such as an eTMF system, a laboratory device, or other information system.
- A centralised document or data repository within an organisation, such as a SharePoint server or ERDMS.
- A dedicated data archiving and digital preservation system, for example deployed in house or provided as a cloud hosted service.
Given the requirements for long-term Data Integrity, it is unlikely that the requirements will all be met by leaving data in a live system or by using a centralised generic solution such as SharePoint. These systems are focussed on data creation and processing so may well be good homes for the data in the early stages of the data lifecycle, including as an initial home for archived data (this is recommended by the GXP guidelines in some cases such as for dynamic data); however, in the long-term it is likely that a specific digital preservation solution will be needed.
Below is a reminder of the ALCOA+ principles as outlined in the Data Integrity chapter.