A Data Manager is importing lab data for a study. The lab data and the associated audit trail is kept at the central lab. What is necessary to maintain traceability of the transferred data at the Data Manager's location?
Maintaining traceability of external data imports (such as laboratory results) is a fundamental principle of clinical data management. According to the GCDMP (Chapter: External Data Transfers and Integration), Data Managers must retain an unaltered copy of the raw data exactly as received from the vendor.
This archived version serves as a reference for:
Data provenance verification,
Audit trail review, and
Discrepancy resolution between vendor and study database.
Since the central lab maintains its own audit trail, the Data Manager's responsibility is to preserve the original data transmission file before applying transformations, merges, or validations.
Options A, C, and D describe procedural safeguards but do not meet the regulatory requirement of traceable data lineage. Only option B (Maintaining a copy of the data as received) ensures compliance with ICH E6(R2) and FDA 21 CFR Part 11 standards for data traceability and integrity.
Reference (CCDM-Verified Sources):
SCDM GCDMP, Chapter: External Data Transfers and Integration, Section 5.2 -- Data Traceability and Version Control
ICH E6(R2) GCP, Section 5.5.3 -- Data Integrity and Source Data Verification
FDA Guidance for Industry: Computerized Systems Used in Clinical Investigations, Section 6.4 -- Source Data Traceability and Archiving
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