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White paper - Automation Change Management for Regulated Industries

Achieving Part 11 Compliance

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Section # Requirement Compliance/Documentation/Comments<br />

AutoSave Software<br />

B/11.30<br />

B/11.50<br />

(a)<br />

Controls <strong>for</strong> open systems<br />

Persons who use open systems to<br />

create, modify, maintain, or transmit<br />

electronic records shall employ<br />

procedures and controls designed to<br />

ensure the authenticity, integrity, and, as<br />

appropriate, the confidentiality of<br />

electronic records from the point of their<br />

creation to the point of their receipt. Such<br />

procedures and controls shall include<br />

those identified in § 11.10, as<br />

appropriate, and additional measures<br />

such as document encryption and use of<br />

appropriate digital signature standards to<br />

ensure, as necessary under the<br />

circumstances, record authenticity,<br />

integrity, and confidentiality.<br />

Signature manifestations<br />

Signed electronic records shall contain<br />

in<strong>for</strong>mation associated with the signing<br />

that clearly indicates all of the following:<br />

(1) The printed name of the signer<br />

(2)<br />

(3)<br />

(b)<br />

The date and time when the signature<br />

was executed; and<br />

The meaning (such as review, approval,<br />

responsibility, or authorship) associated<br />

with the signature.<br />

The items identified in paragraphs (a)(1),<br />

(a)(2), and (a)(3) of this section shall be<br />

subject to the same controls as <strong>for</strong><br />

electronic records and shall be included<br />

as part of any human readable <strong>for</strong>m of the<br />

electronic record (such as electronic<br />

display or printout).<br />

N/A<br />

The Activity Log contains the User ID<br />

associated with each event/action.<br />

The Activity Log contains a date/time stamp<br />

associated with each event/action.<br />

The Activity Log contains the details of the<br />

events/ actions per<strong>for</strong>med (approval,<br />

responsibility, authorship).<br />

The Activity Log contains the User ID/time<br />

stamp and the details of the action<br />

per<strong>for</strong>med associated with each<br />

event/action.<br />

10

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