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Data Integrity in GMP – Operational Guide to Governance, Audit Trail Review and QC Laboratories

Data Integrity in GMP – Operational Guide to Governance, Audit Trail Review and QC Laboratories

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First edition · September 2026
No official source gives you an audit trail review frequency. This guide gives you the way to justify yours.
221 pages of verified method on data governance, the data lifecycle, audit trail review and the QC laboratory. With 18 editable tools built to be completed and justified, not adopted as they are.
221 PAGES25 CHAPTERS IN 6 PARTS18 EDITABLE TOOLS60 VERIFIED SOURCES259 CITABLE CLAUSESIT + EN
THE GUIDE
221 pages, 25 chapters, 6 parts
From the verified regulatory framework to the QC laboratory system by system. Every regulatory statement carries the clause, the date and the status of the text behind it.
THE TOOLKIT
18 editable tools, in English and Italian
Eleven Excel workbooks and seven Word documents. No frequency, threshold or retention period is pre-loaded: every site-dependent field sits next to the field for its rationale.
UPDATES
Lifetime, included in the price
When the 2025 EU drafts are adopted, or a source changes edition, you receive the new version of guide and toolkit at no extra cost.

The 18 tools in the toolkit

Each tool exists because there is a decision the site has to be able to defend. Supplied in English and in Italian.
EXCEL 01 · Data Integrity Gap Assessment
Where you stand against the verified clauses, clause by clause, with evidence and residual gap.
EXCEL 02 · Systems and Data Flow Inventory
The perimeter of governed data: where it originates, where it lives, which audit trails exist.
EXCEL 03 · DIRA with scoring and remediation plan
The risk assessment that makes every downstream choice defensible.
EXCEL 04 · Audit Trail Criticality Matrix
From trail criticality to review cadence, with the reasoning kept on the record.
EXCEL 05 · Audit Trail Review Register
One register for the whole site: no coverage gaps created by parallel logs.
EXCEL 06 · QC Data Review Checklists by system type
What the analyst checks and what the second person checks, system by system.
EXCEL 07 · Access and Privilege Review
Accounts, roles, administrative privileges and shared logins, reviewed in writing.
EXCEL 08 · Backup and Restore Test Log
The documented restore test, not just the backup that shows as completed.
EXCEL 09 · Retention and Archiving Schedule
Every retention period sitting next to the source that actually sets it.
EXCEL 10 · 2025 EU Drafts Readiness Table
What you already do for your own reasons and what you would do only for an unadopted text.
EXCEL 11 · DI Deviation and CAPA Tracker
Data integrity events from detection through to the effectiveness check.
WORD 12 · SOP Data Governance and Data Integrity
Roles, source citation rules, how data integrity events enter the quality system.
WORD 13 · SOP Audit Trail Review
How a trail is actually reviewed: what you look at, how you search, how you record the outcome.
WORD 14 · SOP Data Review in QC
Primary and secondary review of analytical data, printouts and hybrid systems included.
WORD 15 · Audit Trail Review Form
The point evidence of a single review: scope, outcome, date and signature.
WORD 16 · Data Integrity Policy
Which attribute set the site adopts, from which source and with which status.
WORD 17 · Data Integrity Master Plan
Risk, remediation, training, self-inspection and indicators held together in one plan.
WORD 18 · DIRA Report
The report you put on the table when an inspector challenges a choice.

You can use it from Monday morning

Eight real situations on the floor, with the tool and the chapter that resolve each one.
THE SITUATIONTOOL AND CHAPTER
You have to justify how often you review audit trailsTools 04 and 13 · Chapter 12
The inspector asks for evidence of the reviews already doneTools 05 and 15 · Chapter 13
A reintegrated chromatographic peak is challengedTools 06 and 14 · Chapters 16 and 20
Balances and pH meters on the floor have no audit trailTools 03 and 18 · Chapter 19
You cannot say which systems generate GMP data or where it livesTool 02 · Chapters 4 and 5
You have to state how long you keep what, and whyTool 09 · Chapter 22
A data integrity observation lands and has to be closedTools 11 and 18 · Chapters 23 and 24
You are asked whether the site is ready for the revised Annex 11Tool 10 · Appendix D
HOW THE SOURCES ARE HANDLED
No statement without the clause, the date and the status of the text
  • At 6 September 2026 the 2025 EU drafts of Annex 11, Chapter 4 and Annex 22 are not adopted: the text in force is still the Annex 11 of January 2011. In the guide the drafts carry the [DRAFT] label and never enter a requirement.
  • The argument that carries the book is a textual verification: no official source sets a numeric audit trail review frequency. Annex 11 clause 9 only says “regularly”; the FDA, in the December 2018 Data Integrity Q&A, ties the review to the record before release. The frequency is justified through risk assessment, and the guide shows how.
  • Where sources diverge, the divergence is mapped rather than quietly resolved: 10 documented divergences. MHRA uses ALCOA and not ALCOA+; the 2025 draft Annex 11 uses ALCOA+ with nine attributes while the draft Chapter 4 uses ALCOA++ with ten; no FDA document governs manual integration of chromatographic peaks in a CGMP context.
  • 60 sources in the register in Appendix A and 44 documents excluded with the reason stated: superseded editions, documents the industry cites that do not exist, content that cannot be verified. 259 citable clauses consolidated and 1,155 status labels per language.
  • No operational value is pre-loaded in the toolkit: where you would expect a number you find a field to complete and, beside it, the field for its rationale. A pre-loaded number becomes the site default that nobody can trace back to a source.

Inside the guide

  • Part I — The framework and the principles. Who requires what as at 2026, source by source; ALCOA, ALCOA+ and ALCOA++ compared; the definitions of data, raw data, metadata and true copy that actually exist; static records, dynamic records and hybrid systems. Chapters 1–5.
  • Part II — Governance and the data lifecycle. Roles and policy, the lifecycle stage by stage with risks and expected evidence, the DIRA step by step, the link into the quality system and into training. Chapters 6–10.
  • Part III — Audit trail and review. The anatomy of a trail, how you decide what is critical, the review step by step in its two cadences, review in production, and the red flag catalogue with what to verify before concluding. Chapters 11–15.
  • Part IV — The QC laboratory, system by system. HPLC and GC chromatography, chromatography data systems in a vendor-neutral treatment, LIMS and ELN, instruments with no audit trail and their compensating controls, primary and secondary data review, data integrity in OOS and OOT investigations. Chapters 16–21.
  • Part V — Retaining it and proving it. Backup, integrity verification and documented restore testing, archiving and retention attributed to the correct source, data integrity deviations, inspection readiness area by area. Chapters 22–24.
  • Part VI — Cases and appendices. Four applied scenarios, openly fictional, from the problem to the evidence, plus the source register, the 50-entry glossary, the toolkit overview and the readiness table on the 2025 EU drafts. Chapter 25 and Appendices A–D.
FREE PREVIEW
Read 20 pages before you decide
About 7% of the text: the full table of contents, a complete chapter and the toolkit overview. 20 pages in the English edition, 21 in the Italian one.

Specifications

FormatA4 PDF, searchable and printable
Length221 pages (EN) · 223 pages (IT)
Structure25 chapters in 6 parts, plus 4 appendices
Toolkit18 editable tools: 11 Excel and 7 Word, in English and in Italian
LanguagesEnglish edition and Italian edition: choose your language at checkout
Sources60 in the register, with 44 documents excluded and the reason given · regulatory verification closed at 6 September 2026
Glossary50 entries, each with its source alongside
Preview20 pages (EN) and 21 pages (IT), about 7% of the text
UpdatesLifetime, included in the price
DeliveryDigital download immediately after purchase
EditionFirst edition, September 2026
WHO IT IS FOR QA Managers · QC Analysts · Data Owners · IT and CSV Specialists · Data Reviewers · laboratory supervisors
GuideGxP is an independent publisher and is not affiliated with any regulatory authority. This guide is training and documentation material: it is not legal or regulatory advice and it does not replace the site’s own procedures or the judgement of its quality unit. Sources are cited with edition, date and status as at the verification date of 6 September 2026. Digital product: nothing is shipped physically.
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DECLARED REGULATORY BASIS

Built on the most up-to-date official sources.

Every guide is built from the official sources current at the editorial verification date stated in the document. The editions, revisions and cut-off dates used are declared and checked again for every new release; requirements are kept distinct from GuideGxP operational interpretation.

Main references for this guide EU GMP · ICH · PIC/S · FDA/EMA guidance applicable to the topic
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  • Explicit editorial verification date
  • Requirements separated from practical recommendations

GuideGxP is an independent publisher and is not affiliated with, approved by or sponsored by the authorities and organisations cited.

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