Data Integrity
& Part 11

Leaders in Defensible GxP Data

Why Data Integrity Matters

An Inspector Who Can't Trust One Record Can't Trust Any of Them.

Every batch you release, every result you file, every signature you rely on is only as good as the data behind it. It takes one shared login, one audit trail nobody reviews, one result quietly overwritten, and the inspection stops being about that record and becomes about all of them. A decade of FDA warning letters has been built on exactly this, and the finding is rarely the failure itself; it is the absence of a system that would have caught it. We build the controls, the governance, and the culture that make your data trustworthy by design and defensible under inspection.

The Standard

Every Record, Held to Nine Principles.

ALCOA+ is the framework every major regulator, the FDA, EMA, MHRA, and PIC/S, uses to decide whether your data can be trusted. It is also the lens we assess your systems through, principle by principle, before an inspector does.

A Attributable Every record ties to a person and a moment.
L Legible Readable and permanent for its entire retention.
C Contemporaneous Captured as the work happens, not rebuilt after.
O Original The first record, or a verified true copy of it.
A Accurate True to the result, with no silent correction.
Plus Four
+ Complete Every result, including the failures and repeats.
+ Consistent In sequence, with timestamps that agree.
+ Enduring Stored to outlast the system that created it.
+ Available Retrievable the moment an inspector asks.

A 483 citing data integrity? The response you file in the first weeks sets the tone for everything after.

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Capabilities

Six Disciplines That Make Data Trustworthy by Design.

From the first gap assessment to the culture that keeps records clean between inspections, we cover the full span of data integrity and Part 11 compliance.

Risk & Gap Assessment

You Cannot Fix What You Have Not Honestly Measured.

A data integrity assessment is only useful if it finds what an inspector would. We walk your systems the way FDA does: mapping how data is created, changed, and stored; watching the work happen; interviewing the people who do it; and testing whether the controls you documented actually hold. Every finding is ranked critical, major, or minor and tied to a specific ALCOA+ failure, so you get a prioritized remediation plan, not a list of everything that could theoretically go wrong.

What We Assess

  • Data-flow mapping across systems and paper-hybrid processes
  • System-by-system evaluation against ALCOA+
  • Access controls, shared logins, and privilege review
  • Audit trail configuration and review practices
  • Documentation practices and good-recordkeeping gaps
  • Findings ranked critical / major / minor with rationale
  • Prioritized, risk-based remediation roadmap
Part 11 & Annex 11 Compliance

Part 11 Is Not a Checkbox. It Is a Set of Controls That Have to Work.

Making an electronic record equivalent to a signed piece of paper takes real controls: unique identities, secure and reviewable audit trails, signature manifestations that hold up, and copies you can actually produce. We assess your systems against both 21 CFR Part 11 and EU Annex 11, separate the requirements that genuinely apply from the ones that don't, and specify the controls that make your records defensible on both sides of the Atlantic.

What We Cover

  • 21 CFR Part 11 and EU Annex 11 gap assessment
  • Electronic records and electronic signature controls
  • Unique user identity and access management
  • Audit trail requirements and configuration
  • Open- vs closed-system determination and controls
  • Legacy and hybrid-system Part 11 strategy
  • Vendor and cloud (SaaS) Part 11 assessment
Audit Trail Review

The Audit Trail Only Protects You If Someone Reads It.

An unreviewed audit trail is worse than none: it proves you could have seen the problem and didn't. Yet reviewing every entry in every system is impossible, so most programs quietly stop. We design audit trail review that is risk-based and actually sustainable, focusing effort on the entries that matter, defining what a reviewer looks for, and building it into the batch-release and periodic-review workflows so it happens by default rather than by heroics.

What We Build

  • Risk-based audit trail review strategy and frequency
  • Definition of critical vs. non-critical audit trail data
  • Reviewer procedures: what to look for and when
  • Integration into batch release and periodic review
  • Exception handling and escalation pathways
  • Review-of-review and quality oversight
  • Tooling and reporting to make review sustainable

Standing up a new system and want Part 11 built in, not bolted on later? Start before validation.

Design It In From the Start
Computer System Validation

Validation Should Prove the Controls Work, Not Fill a Binder.

Too much validation documents everything and assures nothing, burning months to produce paper an inspector never asked for while the data-integrity controls go untested. We run risk-based CSV and Computer Software Assurance the way the guidance actually intends: focus the testing where a failure would corrupt data or a decision, lean on vendor evidence where it is credible, and produce a validation record that proves the controls your data depends on actually function.

What We Validate

  • Risk-based CSV and Computer Software Assurance (CSA)
  • GAMP 5 category-driven validation strategy
  • Data-integrity controls verification and testing
  • Vendor assessment and supplier-evidence leverage
  • Requirements, risk assessment, and traceability
  • Periodic review and revalidation strategy
  • Validation remediation for legacy systems
Remediation & Inspection Response

Fix the Right Things First, and Prove They Stayed Fixed.

Once a data integrity problem is on the record, the response is judged as harshly as the problem. Regulators want to see that you understood the true scope, addressed the highest risks first, and put controls in place so it cannot recur. We build the remediation plan and the CAPA behind it, sequence the work for the biggest risk reduction soonest, and assemble the evidence that turns "we fixed it" into something an investigator can verify.

What We Drive

  • Scope and impact assessment of the integrity failure
  • Risk-prioritized remediation planning and sequencing
  • CAPA development and effectiveness checks
  • Interim controls while permanent fixes land
  • Remediation of historical data and records
  • Evidence packages for inspection and response
  • Independent verification that findings stayed closed
Governance, Training & Culture

Integrity Is a Habit Before It Is a Policy.

The companies that pass data integrity inspections are not the ones with the thickest SOPs; they are the ones where doing it right is simply how work gets done. We build the data governance program that gives integrity an owner, clear roles, and real oversight, then deliver the training that makes people understand not just the rule but the reason, so the culture holds up on the day nobody is watching, which is the day it matters.

What We Establish

  • Data governance framework, roles, and ownership
  • Data integrity policies and supporting SOPs
  • Data-integrity risk register and monitoring
  • Role-based training for the floor and the lab
  • Management review and data-governance metrics
  • Data-integrity culture and behavior programs
  • Ongoing monitoring and periodic reassessment
Specialty Engagements

The Two Situations That Test a Program Hardest.

A regulator already at the door, and a technology landscape moving faster than the rules: each demands more than a standard compliance pass.

Warning Letter & Consent Decree Response

When FDA Has Already Written It Down.

A data integrity warning letter, or a consent decree, changes the stakes entirely: independent scrutiny, defined timelines, and a burden of proof that sits with you. We help build the response that regulators actually credit, running the independent data integrity investigation, quantifying true scope across affected products and periods, and standing up the remediation program that has to satisfy a skeptical agency, not just an internal reviewer.

Included Capabilities

  • Independent data integrity investigations
  • Warning letter and consent decree response strategy
  • Third-party expert and auditor coordination
  • Retrospective data review across products and periods
  • Comprehensive corrective-action program design
  • Progress reporting and commitment tracking to FDA
Legacy & Cloud Systems

Part 11 in a Stack the Rule Never Imagined.

The regulation was written for systems that no longer exist, and now has to govern SaaS platforms, shared cloud infrastructure, and instruments older than the standard itself. We bridge that gap: bringing legacy systems into a defensible state without ripping them out, and assessing modern cloud and vendor platforms so you can adopt them with the audit trails, controls, and vendor evidence that keep them compliant.

Included Capabilities

  • Legacy-system data integrity gap and remediation
  • Standalone-instrument and spreadsheet controls
  • Cloud and SaaS Part 11 and vendor assessment
  • Shared-infrastructure and multi-tenant risk review
  • Data-migration integrity and verification strategy
  • Digital-transformation compliance-by-design support
Who You're Working With

People Who Have Been Inspected and Have Inspected.

Our data integrity leads have sat on both sides of the audit: running quality systems that passed FDA and MHRA inspections, and reviewing data integrity from the regulator's chair. They have written the remediation plan that closed a warning letter and validated the systems that never earned one. You get the practitioner who has done it, not a checklist.

Inspection-Tested Quality Leaders

Quality and compliance leaders who have carried GxP systems through FDA, EMA, and MHRA data integrity inspections and lived with the outcome.

Agency-Side Perspective

Practitioners who have evaluated data integrity from the regulator's side and know which gaps become findings and which findings become warning letters.

CSV & Systems Depth

Validation and computerized-systems specialists fluent in GAMP 5, CSA, and the platforms that run GxP, from LIMS and MES to cloud QMS.

Remediation Under Pressure

Leaders who have run data integrity remediation against a regulator's clock, where the plan has to be right and the evidence has to hold.

Work With Us

Make Your Data Defensible Before Someone Tests It.

Tell us where you stand: a proactive assessment, a system to validate, or a finding to remediate. We'll match you with a senior data integrity lead and respond within one business day. All inquiries are strictly confidential.

Schedule a Call Send a Detailed Inquiry
Insights & News

Thought Leadership on Data Integrity.

Our team's perspectives on ALCOA+ in practice, audit trail review that actually happens, and Part 11 in a cloud world: coming soon. In the meantime, reach out directly with a question you'd like to see addressed.

Coming Soon

Audit Trail Review Without the Impossible Workload

How to make risk-based review real instead of a policy nobody can follow.

Coming Soon

What Turns a Gap Into a Warning Letter

The difference between a data integrity finding FDA notes and one it escalates.

Coming Soon

Part 11 for Systems That Live in the Cloud

Applying a 1997 rule to SaaS platforms without pretending they're the same.