Implementing Pharmaceutical Data Integrity Principles In an Era of Advanced Technology
Introduction
Data integrity is of paramount importance in pharmaceutical industry as seen through the rigorous guidelines which are issued by regulatory bodies such as the ICH and USP. With the advancement in technologies such as cloud computing and artificial intelligence, more challenges arise on how best these technologies can be incorporated in data management whilst adhering to set guidelines. This article will discuss key principles in data integrity and how best it can be implemented in an era of fast-paced technological advancements. Enjoy
Data Integrity
According to WHO, pharmaceutical data integrity means data must be complete, consistent, accurate, reliable and trustworthy throughout its lifecycle
Key Principle: ALCOA+ Framework
Attributable
Data should be traced to the person who created it to the exact time and date of action. Data should have an individual responsible for its recording or retrieval. This is responsible for accountability
Legible
Data recorded should be permanent and recorded in a durable medium. This applies to both handwritten and electronic records
Contemporaneous
Data should be recorded at the exact time of action or observation. This prevents backdating or delayed entries which may result in omission of important data
Original
Data should be available be the original record form or a certified copy of the original
Accurate
Data recorded should be a representation of the true action or observation which occurred, free from errors or editing without justification and documentation.
Consistency
Data provided should be coherent throughout the process being recorded, showing a coherent timeline of events.
Complete
All the data which is required to be recorded should be captured and reported
Enduring and Available
Data should be able to last throughout its required lifetime and be able to be retrieved easily when required
Using Technology in Implementing Data Integrity Principles
Cloud-Based Data Management
Pharmaceutical companies can adopt validated cloud solutions for storing laboratory, clinical or manufacturing data. This ensures data is legible, contemporaneous, original, consistent enduring and available
This can be achieved by ensuring:
Data encryption at all times
Automated data backup and disaster recovery solution
Sourcing an approved GxP-compliant cloud provider
Secure Access Control
Secure access control ensures data remains attributable
This can be done by having:
User electronic signatures
Multifactor authentication
Biometric login for critical systems
AI-driven anomaly detection to flag suspicious logins or data changes
Audit trails and Metadata capture
Ensures data remains contemporaneous, complete, consistency and accurate
This is done by having:
Cloud logs automatically captured and monitored
Audit trail software integrated into the main pharmaceutical system
AI-driven anomaly detection to flag unusual trends in data modification
AI in Validation and Monitoring
Ensures data is accurate
This is achieved by:
Machine learning for predictive data quality monitoring
Natural language processing (NLP) to check compliance of free text entries with SOP standards
Data Governance Framework
Data should be managed during its lifetime to ensure its in line with the company policies and SOPs. Internal pharmaceutical regulatory departments can use such technologies to ensure that the whole organization is in compliance with set guidelines by authority on data integrity
Integration of technology involves:
Digital SOP platform
Cloud dashboards to track compliance metrics
AI-based compliance bots to scan data for gaps in integrity
Cybersecurity Integration
As companies use cloud computing and AI tools, it is important that they are able to detect and prevent data breaches
This can be done by:
AI-powered intrusion detection system
Zero trust architecture
Endpoint detection and response (EDR) tools to secure lab instruments and computers connected to network
Data Lifecycle Management
This helps in keeping data enduring & available
Data lifecycle management can be achieved by:
Cloud archiving with retention locks
Automated alerts before data expiry
Blockchain timestamping for long term authentication
Hybrid Systems Validation
The use of cloud and AI systems will need to be validated so as to be accepted by regulatory bodies
System validation of such technologies will involve:
AI/Machine Learning frameworks
Continuous performance qualification as the technologies evolve with automated scripts
Following GAMP 5 guidelines for computerized system validation
Staff Training
Since staff is responsible for operating these technologies, it is important that they understand how to use such technologies and importance of digital compliance requirements
This often involves:
E-learning platforms with interactive AI tutors
Cloud based competency tracking
Digital simulations of data breaches scenarios
Conclusion
No doubt that technologies such as cloud computing and Artificial Intelligence are defining data integrity practices in pharmaceutical sector. Nonetheless, the ALCOA+ principles which are the cornerstone of data integrity still applies even when using such technologies.
It is therefore the responsibility of the pharmaceutical company to ensure the ALCOA+ principles are embedded in their digital systems, ensuring strong cybersecurity and creating a culture of digital compliance