Completion↦Data Management↦Archiving↦Requirement
What is it? Why is it important?
Archiving the study database (eCRF) makes its information accessible for potential future use. A request to access archived data might arise from:
- A request for data sharing
- Safety concerns requiring that participants be re-contacted
- Allegations of fraudulent behaviour
- Inspections by EC and RA (e.g. Swissmedic)
Archiving is not limited to the study database and its CDMS, but includes all records that describe the method, conduct, and results of the study (e.g. study protocol, essential documents, monitoring reports, statistical analysis). In addition, a description of the risk management of the study with its implemented risk-control-measures must be archived (e.g. risk-based QMS)
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Archived records can either be hand-written, electronic, magnetic, optical, scans, x-rays, or electrocardiograms.
Archiving must guarantee that:
- Data integrity is maintained over the entire archiving period (e.g. completeness, legibility, inalterability).
- Electronic data or documents transferred to another (more current) medium, has its transfer system validated
- The archive is access restricted but remains accessible during the entire archiving period. Only authorised study staff retain access to the archive. Restricted access prevents theft, vandalism, forgery, destruction and loss of records
- Records removed or returned from/to the archive are documented and traceable (e.g. dated and signed with details on relevant documents)
- Archiving premises are safe from any potential damage, with ongoing protection against fire, humidity, and rodent infestation
What do I need to do?
As a SP-INV, provide the Site-INV with an archiving SOP that defines:
- What study records to archive
- The process on how to archive electronic data
- Means on how to document retrieved and returned records
- Expected duration of archiving
- Expected requirements for archiving premises (e.g. access control, protection against fire, humidity, and rodent infestation)
- Destruction procedures (e.g. certificate of destruction). Notify the study-site when the archiving period has ended and documents can be destroyed
In the event of an audit or inspection during the archiving period, ensure auditors or inspectors have access to all required records on demand.
The required archiving period depends on study type, such as:
- 10 years for IMP studies
- 15 years for studies with implantable MD
- 20 years for studies with transplant products, blood or blood products
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Guidelines for the archiving of study data:
- Archive all clinical-, meta-, administrative- and reference data in standard open system formats (e.g. CDISC, ODM storing system)
- Archive all study components including clinical data, CRF (electronic and paper), validation records, and regulatory documentation
- Store audit-trails in open format file (e.g. text file)
- Retained in an archive facility system documentation for any applications used to collect or manage clinical data
- Print and store in a central document library all reports describing the metadata of the study, including data structures, edit check descriptions; lab-import specifications
- Archive system security reports, including user listings, access rights and the dates of authorisation
- Include all program code(s) for edit checks, functions and sub-procedures with a copy of the version control information.
Where can I get help?
Your local CTU↧ can support you with experienced staff regarding this topic
Basel, Departement Klinische Forschung, CTU, dkf.unibas.ch
Lugano, Clinical Trials Unit, CTU-EOC, www.ctueoc.ch
Bern, Clinical Trials Unit, CTU, www.ctu.unibe.ch
Geneva, Clinical Research Center, CRC, crc.hug.ch
Lausanne, Clinical Research Center, CRC, www.chuv.ch
St. Gallen, Clinical Trials Unit, CTU, www.kssg.ch
Zürich, Clinical Trials Center, CTC, www.usz.ch
External Links
GCDMP – see in particular
- Chapter “Clinical Data Archiving”
CDISC – see in particular
- ODX-XLM – Vendor-neutral, platform-independent format for exchanging and archiving clinical and translational research data
*References
ICH GCP E6(R2) – see in particular guideline
- 5.5. Trial management, data handling, and record-keeping