The 25‑Year Challenge: Risks You Must Actively Manage
Retaining trial records for 25 years introduces a materially different risk profile compared to short‑term archiving. Without proactive management, sponsors face multiple risks that can change and increase over time.
Key risk elements include:
1. Old Hardware:

Data you can’t access is data you don’t have. If your files are stored on old or obsolete hardware, like legacy servers, tapes, or proprietary eTMF exports, the problem is access. The files might still exist, but without the right device or drive, you simply can’t open them. Wait too long, and the media can degrade, making recovery impossible.
“There had been no detailed assessment of the systems used for essential documents” MHRA - FOI Request from Arkivum for MHRA Inspection Findings 2026
2. Old Software:

Readable today doesn’t guarantee readable tomorrow. If your files were created and the software is now obsolete, like old statistical tools or discontinued office programs, the problem is readability. You might be able to access the storage, but the software needed to open or understand the files no longer works. In many cases, converting them later may be too late to preserve the original content.
“There was no process in please for the future proofing of documents that have been archived on CDs in an electronic format. This includes the spreadsheets and data files from the study which had been archived”.
MHRA - FOI Request from Arkivum for MHRA Inspection Findings 2026
3. Exports and migration:

Lost context means lost integrity. When systems are changed or data is moved, important details can be lost. If metadata, audit trails, or links between records are not kept, trial records and data may become incomplete. This can make the records difficult to defend during an inspection.
“Archived data from the databases was stored in PDF fomat and only included patient data and associated audit trails. This data was not dynamic and therefore would prove to be difficult to use to verify study conduct. In addition, data relating to study audit trails were not collated”.
MHRA - FOI Request from Arkivum for MHRA Inspection Findings 2026
4. Vendor dependency and lock-in:

Long-term access needs independence from suppliers. If you cannot fully extract your records from a system, you may become dependent on the vendor. Changes in pricing, system upgrades, contract terms, company ownership, or even supplier failure can put long-term access to trial records at risk. Lock-in is a reality for many organisation when live systems are used for long-term retention.
5. Organisational change:

When ownership shifts, accountability can break. Mergers, acquisitions and system retirements can create ownership gaps, broken chains of custody and undocumented transfers of responsibility.
“There was no documentation in place to identify the named archivist(s) for paper and electronic records, or whether the requirements of the UK regulations were recognised in Archiving processes and individual job requirements/descriptions”.
MHRA - FOI Request from Arkivum for MHRA Inspection Findings 2026
6. Privacy and security obligations:

Long-term data protection is a moving target. Personal data must remain protected for decades under evolving regulatory regimes.
“There was no documentation in place to identify the named archivist(s) for paper and electronic records, or whether the requirements of the UK regulations were recognised in Archiving processes and individual job requirements/descriptions”.
MHRA - FOI Request from Arkivum for MHRA Inspection Findings 2026
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