What are the key data security and compliance considerations labs must address when adopting connected tools?
Gunnar Danielson: One of the fundamental concepts to consider is the predicate rule. This rule originates from the regulations that dictate how labs should operate, traditionally with paper-based systems. When working with paper, you had to ensure double-checking, validation, signoffs, and clear records of any changes, including who made them, when, and why.
The same requirements apply when you transition to digital technology. In other words, everything you did on paper must be replicable electronically. Your electronic systems must be capable of showing a clear audit trail of all actions taken, maintaining the same level of accountability and traceability.
If your electronic system does not inherently provide these capabilities, you must develop procedural controls to address the gaps. These controls can either be procedural or technical. Ideally, the new tools you adopt will come equipped with all the necessary technical controls. However, if they do not, you will need to establish procedural controls, which could be either paper-based or people-based, to ensure compliance.
How can labs ensure that they meet regulatory requirements while modernizing their infrastructure?
Tobias Pfister: It's essential for labs to understand that compliance is ultimately their responsibility. While we can provide instruments, software, and training, the lab must comprehend its own processes and how they align with regulatory requirements.
A key point is that compliance is not about the system alone; it's about the entire process and the way work is conducted, whether digital or not. Labs need to have a thorough understanding of the regulations and ensure that their workflows are in line with these requirements.
An electronic system can indeed offer significant advantages. It can provide a host of technical controls that minimize the need for manual, paper-based processes. This, in turn, can lead to increased productivity by reducing the administrative burden. However, labs should not be under the illusion that simply purchasing an electronic or digital system will make them compliant.
It's crucial for labs to have a deep understanding of the systems they use and how these systems integrate with their processes to meet regulatory standards. They need to know how to apply these systems effectively to ensure compliance with all relevant regulations.
Ultimately, the goal is to leverage electronic systems to enhance compliance and efficiency, but this requires a comprehensive understanding of both the technology and the regulatory landscape.
What measures can labs take to protect sensitive data and maintain data integrity?
What we're discussing is essentially data integrity. Labs must understand that using a system properly is just like managing paper records. It's really no different. The system provides technical controls to ensure compliance with data integrity rules, but a system in itself does not guarantee data integrity or compliance. It's merely a tool.
The lab is responsible for data integrity. The lab must work according to principles of data integrity and compliance to manage risk effectively. It's crucial to recognize that these tools are there to help, but they do not inherently supply data integrity. Unfortunately, a lot of marketing materials falsely claim that instruments are certified by the FDA to be data integrity compliant, which is misleading. People need to understand that they must use these tools correctly within their procedures to maintain data integrity.
Regarding data safety and security, especially in regions like Europe, where regulations such as GDPR exist, there are several important measures to consider. Digital data, like physical lab notebooks, needs to be securely stored and backed up. This ensures that data can be restored in case of a disaster. Automated solutions for regular backups are available to help ensure data is not lost.
Access control is another critical aspect. Systems should provide different levels of access to ensure that not everyone can see all the data. This is important for maintaining data sensitivity and integrity. Additionally, the location of data storage is significant. The server or database could be in the US, Switzerland, China, or another location, and labs must understand the rules that apply based on where they are operating.