Sunday, October 31, 2021

Learn how to accelerate your FDA CFR Title 21 deploymen

Although there is no certification for complying with CFR Title 21 Part 11, the following Microsoft enterprise cloud services have undergone independent, third-party audits, which may help customers in their compliance efforts. These services include:

 

Azure: Cloud Services, Storage, Traffic Manager, Virtual Machines, and Virtual Network

Azure DevOps

Intune

Dynamics 365 and Dynamics 365 U.S. Government

Office 365 and Office 365 U.S. Government

Audits, reports, and certificates

The audit reports for SOC 1 and SOC 2 Type 2, ISO/IEC 27001 and ISO/IEC 27018 standards attest to the effectiveness of the controls Microsoft has implemented and may help customers in their compliance with FDA CFR Title 21 Part 11.

 

Frequently asked questions

To whom does the standard apply?

 

FDA CFR Title 21 Part 11 applies to organizations with products and services that deal in FDA-regulated aspects of the research, clinical study, maintenance, manufacturing, and distribution of life science products.

 

How do Microsoft enterprise cloud services demonstrate compliance with FDA CFR Title 21 Part 11?

 

Using the formal audits prepared by third parties for SOC 1 Type 2, SOC 2 Type 2, ISO/IEC 27001, and ISO/IEC 27018, Microsoft is able to show how relevant controls noted within these reports address the requirements.

 

Audited controls implemented by Microsoft help ensure the confidentiality, integrity, and availability of data, and correspond to the applicable regulatory requirements defined in Title 21 Part 11 that have been identified as the responsibility of Microsoft. The qualification guidelines for Azure and Office 365 detail how Microsoft audit controls correspond to those requirements.

 

How can I get copies of the auditor's reports?

 

The Service Trust Portal provides independently audited compliance reports. You can use the portal to request audit reports so that your auditors can compare Microsoft's cloud services results with your own legal and regulatory requirement.

 

Can I use Microsoft's compliance in the certification process for my organization?

 

Yes. The independent third-party compliance reports of the IEC/ISO 27001, ISO/IEC 27018, SOC 1, and SOC 2 standards attest to the effectiveness of Microsoft controls. Microsoft enterprise cloud customers may use the audited controls described in these related reports as part of their own CFR Title 21 cfr part 11 on electronic records analysis and qualification efforts. Customers who build and deploy applications subject to FDA regulation are responsible for ensuring that their applications meet FDA requirements.

 

What are Microsoft's responsibilities for maintaining compliance with this standard?

 

Microsoft ensures that its enterprise cloud services meet the terms defined within the governing Online Services Terms and applicable Service Level


Agreements (SLAs). These terms define our responsibility for implementing and maintaining controls adequate to secure and monitor the system.

 

Use Microsoft Compliance Manager to assess your risk

Microsoft Compliance Manager is a feature in the Microsoft 365 compliance center to help you understand your organization's compliance posture and take actions to help reduce risks. Compliance Manager offers a premium template for building an assessment for this regulation. Find the template in the assessment templates page in Compliance Manager. Learn how to build assessments in Compliance Manager.

 

Resources

Azure GxP Qualification Guidelines

Code of Federal Regulations Title 21

FDA guidance for industry Part 11: Electronic records and signatures

Qualification guidelines for Azure

Qualification guidelines for Office 365

Microsoft Common Controls Hub Compliance Framework

Microsoft Online Services Terms

Microsoft Cloud for Government

Compliance on the Microsoft Trust Center

 

The challenge

The Food and Drug Administration’s (FDA) standards for Title 21 of the Code of Federal Regulations (CFR), also known as the FDA 21 CFR, provide a clear and concise set of regulations.

 

A specific focus of FDA 21 CFR is Part 11, which details regulations for the use of electronic records and electronic signatures. For many companies that rely on digital data to monitor their products, such as those in the pharmaceutical, food and healthcare sectors, ensuring compliance with 21 CFR Part 11 is essential.

 

The most basic definition of 21 CFR Part 11 compliance is the submission of validation documents to the FDA. These materials contain a series of tests and reports to support the assessment that your systems and software are authentic, reliable, and valid.

 

About Us

DATA INTEGRITY

Issued by the FDA (Food & Drug Administration) in 1997, the 21 CFR Part 11 final rule is intended to permit the widest possible use of electronic technology. This is divided into two main sections:

 

Electronic Records

Electronic Signatures

These are a natural extension to the traditional use of paper records. Paper records provide data security and can carry handwritten signatures to indicate that certain data is correct and log events, which took place. Attempted corruption of either the data or signatures is readily detectable.

 

In basic terms the requirement of Electronic Records is to provide secure data which can provide a high level of confidence as would be the case with paper records. Electronic signatures require that both operators and supervisors can electronically identify themselves in such a way as to be equivalent to handwritten signatures. The rule also permits the use of biometrics such as fingerprint or retinal scan devices.

 

The advance in electronic systems offers significant benefits for data retrieval and storage of data. The FDA developed the 21 CFR Part 11 rule to describe what they require to be comfortable that the electronic records and signatures are secure.

 

21 CFR Part 11 Made Easy!

From plant wide data access security management to single, secure recorders – let us help you choose a solution that is right for you.

 

Solutions designed for ease of validation

Minimize validation time and testing by using standard, built-in features to meet the FDA’s 21 CFR Part 11

Data recording at every level, local and plant wide

Never lose your data with cost-effective, multiple recording and secure back-up

Centralised security system provides maintenance of user accounts and passwords from one or multiple locations

Secure local data collection with automatic archiving across your network – truly designed to keep your data safe

Remediation solutions for legacy systems – „Wrap & Comply“

 

Electronic Records

Secure process values and audit trails (alarms, events, operator actions, log-in/log-out, operator notes, electronic signatures)

Protection of data through binary, compressed and check-summed records

Accurate time stamps are ensured using automatic Time Synchronization to a known clock source

Provision for electronically copying data for archive

Export facility providing viewing of secure records in human readable form

 

Electronic Signatures

All user actions can be configured to require signing or require signing and authorization

User specific access according to authority level

Signature element controls unique user signature, password expiry, minimum password length, automatic log-off, automatic disabling and notification of failed login attempts

Ensuring unique users by retiring and not deleting accounts

 

Central Security Manager with full audit trail

Security Manager offers significant operation cost savings and ease of use allowing maintenance of user accounts and passwords from one or multiple locations. If a user needs to change their password they can do so on a local instrument or PC and this will be automatically distributed across all systems to which they have acc

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