Introduction to the Course
Regulations and Guidance for Audit Trails and their Review
- An overview of the regulatory framework: EU, FDA, MHRA, WHO and PIC/S regulations
 - Data life cycle in analytical laboratories
 - Audit Trails in GMP inspections: What are the expectations of the inspector?
 
Audit Trail Review as part of a Data Integrity Strategy
- Define ATR as element of the DI strategy
 - Risk-based approach – how to apply
 - Apply a systematic approach to define ATR
 - Audit Trail Review concepts 
 
Validation of Audit Trail Functionality
- Specification of Audit Trail requirements in the URS: dos and don’ts
 - Documentation of the application configuration for Audit Trail functionality
 - Leveraging the supplier’s development and testing into your validation effort
 - User acceptance testing of Audit Trail functionality
 
Case Study 1: 
Validation of Audit Trail Functionality
- The attendees will review user requirements for Audit Trail functions to highlight good and bad practices and from good requirements design Tests to verify correct functionality
 - Documenting the assumptions, exclusions and limitations of your chosen test approach
 
Audit Trail Review in Context of Second Person Review
- Overview of the analytical process from sample to reportable result
 - Highlight the use of computerised systems and Audit Trails
 - Use technical controls to focus  review effort
 - Audit Trail Review issues for manually entered data into a laboratory system and electronic transfer between systems
 
When is an Audit Trail not an Audit Trail?
- What do we look for in an application for auditing?
 - Which Audit Trail(s) should I review?
 - Event logs vs. audit logs
 
Where do Suppliers help us and where do they let us down?
- What do we expect from the suppliers to support data and Audit Trail Review?
 - Identify and avoid typical pitfalls
 - Data ownership
 - Data packaging and storage – supplier vs. business 
 
Case Study2:
Which Audit Trail to review?
- Attendees will be presented with an overview of the Audit Trails within a chromatography data system and the content of each one 
 - Which Audit Trails should be reviewed and when?
 
What are GMP-relevant Data?
-  Annex 11 requires that audit trails monitor GMP-relevant data – what are GMP-relevant data?
 -  What are critical data and how can they be determined?
 -  Direct/indirect, static/dynamic data
 -  Data, Audit Trail and criticality? 
 
Case Study 3:
Identifying GMP-relevant Data
Developing a matrix for risk-based Audit Trail Reviews. The participants will apply the principles to a list of laboratory records to identify, if they are GMP records to help focus the Second Person review of Audit Trail data.
 
Review of Audit Trail Entries
- Guidance for “regular review” of Audit Trails
 - Process versus system: avoiding missing Data Integrity issues when only focussing on a per system review
 - What are we looking for in an Audit Trail Review?
 - Suspected Data Integrity violation - What do we need to do?
 
Case Study 4:
Reviewing Audit Trail Entries Part 1
- Attendees will be provided with a series of Audit Trail entries at the system level to review. Are there any potential Data Integrity issues to be followed-up?
 
Controls to aid Second Person Review of Audit Trails
- Technical considerations for Audit Trail Review e.g. identifying data that has been changed or modified – how the system can help documenting the audit trail review has occurred
 - Review by exception – how technical controls can help
 - Have you specified and validated these functions?
 
Case Study 5:
Reviewing Audit Trail Entries Part 2
- Attendees will be provided with a series of Audit Trail entries at the data capture and interpretation level to review.  Are there any potential Data Integrity issues to be followed-up?
 
 
Recording from 6/7 May 2025
Duration of Recording: 10h 18min