ICH E6(R3) gives data governance its own section. Annex 1, Section 4, "Data governance: investigator and sponsor", covers safeguarding blinding, the elements of the data life cycle and computerised systems (ICH E6(R3), EMA Step 5). EMA's separate guideline on computerised systems and electronic data in clinical trials covers the same ground in more detail: validation, user management, security and electronic data across the data life cycle (EMA guideline).
Most discussion of Section 4 focuses on EDC and eCOA, the systems that hold participant data. But CTMS and eTMF hold the records that show how the trial was run and overseen, and inspectors read them. The eight requirements below apply to both, with the level of control proportionate to the importance of the data.
|
Requirement |
In CTMS |
In eTMF |
|---|---|---|
|
Fit for purpose and validated |
Monitoring, milestones, deviations |
Filing, QC, approvals |
|
Metadata and audit trail |
Who changed a visit report or issue, and when |
Who filed, approved or replaced a document |
|
Audit trail review |
Changes to monitoring findings |
Changes to approved documents |
|
Attributable corrections |
Reason for changing a deviation record |
Reason for superseding a document |
|
User management |
Access by study, country and role |
Blinded and unblinded access |
|
Security and backup |
Protection of operational data |
Protection of essential records |
|
Transfer and migration |
Moving studies between systems |
CRO-to-sponsor TMF transfer |
|
Retention and access |
Records available after study close |
Archive readable for the retention period |
The responsible party should make sure computerised systems are validated for their intended use, proportionate to risk, and that validation is maintained throughout the system's life cycle, not only at go-live. For CTMS and eTMF, that means validation evidence for configured workflows, not just the vendor's base product.
The audit trail is part of the record. Exports or migrations that carry documents or data without their metadata lose the evidence of who did what and when.
E6(R3) expects review of data and relevant metadata. That requires audit trails a person can read, filtered to the changes that matter, such as edits to monitoring findings or replacement of approved documents.
When a deviation record, monitoring report or filed document is changed, the system should show who made the change, when, and why, without hiding the original.
Access should match each person's role, study and, where relevant, blinding status. Joiners, leavers and role changes are part of GCP compliance, because an account left open after someone leaves is an access-control finding.
Security controls, backup and disaster recovery should be in place and tested, proportionate to the importance of the records the system holds.
Moving a study from one system to another, or transferring a TMF from a CRO to a sponsor, must keep documents, metadata and audit trails together and verify that nothing was lost.
Archived records and their metadata must remain readable and protected from unauthorised change for as long as they must be kept. For the EU TMF, that is at least 25 years.
Cloudbyz CTMS and eTMF are built natively on Salesforce, so platform controls such as role-based and field-level security, audit trails, encryption and event monitoring are available to both. Cloudbyz describes its products as compliant with 21 CFR Part 11 and aligned with GxP and GAMP 5, and holds ISO 27001 certification. eTMF supports QC and approval workflows with electronic signatures and export with metadata and audit trail. Validation scope, audit trail review and access rules still need to be defined and documented by each sponsor or CRO for its own use, proportionate to risk.
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