Electronic Records Life Cycle
Electronic Records Life Cycle
Introduction
E-records, as information objects, have a life cycle that begins “from initial
data generation and recording, through processing (including transformation
or migration), use, retention, archiving, and retrieval.Ӡ
The life cycle is needed to understand the controls necessary to properly
manage e-records and ensure their integrity. Failure to address just one
element of the data life cycle will weaken the effectiveness of the computer
control systems‡ and the e-records integrity–related controls.
Figure 3.1 depicts a typical data life cycle.§ The typical stages associated
with the e-records life cycle are: creation, access, use and reuse, migration,
and physical deletion.
Note that the business requirements that underlie the e-records handling
requirements drive the selection of appropriate supporting technologies. The
technologies pose questions associated with ongoing internal and external
secondary access to records, support the selection of appropriate technologies,
and identify important system migration issues.
Creation
Initial e-records are generated during the Creation Stage as the result of activities.
Some activities have defined boundaries. This means they have a start and
an end point, during which information is recorded either by human action or
by technology, such as process control and data acquisition, on a real-time basis.
There are two important elements during the Creation Stage. One,
whether the raw e-records meets the requirements defined by business
policy, governmental regulations, and by law. Two, that the raw e-record is
correct, reliable, and accurately represents the particular activity recorded.
The “data” collected during the Creation Stage is considered to be “work
in process” similar to draft documents.
An e-record becomes a CGMP record when the e-record is generated to
satisfy a CGMP requirement. The e-record must save “the data at the time of
performance to create a record in compliance with CGMP requirements
Migration†
Data migration is the transporting of e-records from one system to another,
or the transition of data from one state to another. It can occur either in the
active or inactive phase of the e-records life cycle.
If system obsolescence forces a need to transfer e-records from one
system to another, the process must be well documented and its integrity
verified. If e-records are transferred to another data format or system, validation
should include checks that data is not altered in value and/or meaning
during data migration. Conversion of data to a different format is also considered
to be data migration.
Migrated data should remain usable and retain its content and meaning.
Risk assessment is a key instrument in data migration. The system owner
should ensure system audit trails, electronic signatures, and metadata remain
intact after migration. It is the system owner’s responsibility to maintain the
link between the readable audit trail, electronic signatures or metadata, and the
audited data.