Completion↦Documents↦Required Documents↦Doument Archiving
What is it? Why is it important?
Upon study termination, all essential and other relevant documents (e.g. quality documents such as SOPs, WIs, study processes) are archived. The archive must be set-up in a manner that enables the study to be reproducible at any time during the archiving period.
Archiving processes and premises should be in place to:
- Prevent document destruction before the end of the required archiving period (e.g. fire-, humidity-, rodent infestation)
- Ensure premises are access restricted and protected against unlawful access, modification, theft, vandalism and forgery
- Ensure that any removal and retrieval of archived documents is documented and logged
- Allow access and retrieval of documents, should this become necessary (e.g. EC, RA (e.g. Swissmedic) audit or inspection)
Archiving requirements including the required archiving period are defined in the law.
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After study termination, it is required that a study IMP/IMD be retained until the expiry date of the last IMP batch supplied, or the last series of devices used in the study, but at least for:
- 10 years for IMP and IMD studies
- 15 years for studies with implantable devices
- Or otherwise specified in the study protocol
Documents required for the identification and follow-up of study participants, including all other original data must be archived for at least:
- 10 years for IMP and IMD studies
- 15 years for studies with implantable devices
- Or otherwise specified in the study protocol
What do I need to do?
As a SP-INV define and document archiving processes in an SOP.
As a SP-INV or Site-INV:
- Know which documents to archive (check ICH-GCP chapter 8)
- Know the required archiving period applicable to your study
- Create an archiving index with an overview of filed documents
- Store documents in a manner that guarantees legibility over time (electronic and hard copy)
- Ensure to use validated transfer systems when making copies or transferring data to another storage medium (e.g. certified copies of Soure Data (SD))
- Designate a staff member responsible to oversee archiving premises, including the correct implementation of the archiving SOP
Study documents are archived over many years, which might generate archiving costs. Consequently, when planning your study budget, remember to include archiving costs.
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As a Site-INV:
- Follow SOP archiving procedures as provided by the SP-INV, or according to an approved site specific SOP (e.g. binders are clearly labelled with study name, responsible SP-INV, study site, length of archiving)
- Keep a record of archived documents in order to request their destruction at the end of the archiving period. The request and its approval is granted by the SP-INV
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
References
ICH GCP E6(R2) – see in particular guidelines
- 4.9.5 Data Retention
- 8 Essential Documents for the Conduct of a Clinical Trial
Swiss Law
ClinO – see in particular article
- Art. 45 Data retention requirements
ClinO-MD – see in particular
- Art. 40 Document retention requirements