What is it? Why is it important?

Upon study end, study data and documents (e.g. essential documents) are archived.  The aim is to retain the ability to reconstruct the study at some later date.

 

Archiving is the only available mean to verify that the:

 

Regardless whether documents are available as hard copies or in an electronic form, they must:

  • Remain legible during the entire archiving period
  • Be made available to the Ethics Committee (EC) and Swissmedic upon request
  • Be traceable in the event they become removed and returned from/to the archive
  • Be validated when subjected to a transfer medium (e.g. certified copies)

 

Archiving premises must be:

  • Access restricted to prevent theft, destruction, or forgery (e.g. access with personalised badge or key)
  • Protected against fire, humidity, and rodent infestation

More

Documents must be archived in a safe secure place. Archiving must guarantee that:

  • Documents remain legible during the entire archiving period. This includes electronically archived data. If data or documents are transferred to another medium, its transfer system must be validated
  • Only authorised personnel have access to archived study documents and material
  • All documents must be made available to EC/RA upon request
  • Removal and retrieval of archived documents are tracked and documented
  • Premises are protected against fire, humidity, and rodent infestation including access control in order to prevent theft, vandalism, forgery, destruction and loss

What do I need to do?

As a SP-INV:

  • Familiarize yourself with legal archiving requirements (e.g. scope and duration)
  • Provide the Site-INV(s) with an archiving SOP, including instructions on:
    • Documents / data to be archived (e.g. ISF, participant-identification-log)
    • Acceptable archiving premises
    • Procedures for the retrieval and return of archived documents and data
    • Expected duration of archiving
  • Notify the Site-INV(s) when study records are no longer needed. Include destruction procedures (e.g. documentation, data confidentiality)
  • Request a certificate of destruction

 

As a Site-INV:

  • Implement the archiving SOP of the SP-INV
  • As agreed, return selected data and documents to be archived with the SP-INV
  • If applicable, remind the SP-INV when the archiving duration is over
  • Follow required destruction procedures (e.g. documentation on how, when, and where documents were destroyed)

More

Based on the Swiss law, the archiving period of studies with an investigational:

  • Medicinal Product (IMP) is at least 10 years
  • Medical Device (IMD) is at least 15 years

Where can I get help?

Your local CTU can support you with experienced staff regarding this topic

References

ICH GCP E6(R2) – see in particular  guideline

  • 5.5.6 Data retention

ISO 14155:2020 Medical devices (access liable to costs) – see in particular section and annex

  • 8.6 Document retention

ISO 20916:2049 In vitro diagnostic medical devices

Swiss Law

ClinO – see in particular articles

  • Art. 18 Storage of Health-Related Personal Data and Biological Material
  • Art. 45 Data retention requirements

ClinO-MD – see in particular article

  • Art. 40 Document retention requirements
Abbreviations
  • ClinO – Clinical Trials Ordinance
  • ClinO-MD – Ordinance on Clinical Trials with Medical Devices
  • CTU – Clinical Trials Unit
  • ICH GCP – International Council for Harmonisation Good Clinical Practices
  • ISO – International Organization for Standardization
  • ISF – Investigator Site File
  • Site-INV – Site Investigator
  • SOP – Standard Operating Procedure
  • SP-INV – Sponsor Investigator
Completion ↦ Management ↦ Archiving ↦ Storage
Study
Basic

Provides some background knowledge and basic definitions

Basic Protocol
Basic Statistics
Basic Monitoring
Basic Drug or Device
Concept

Starts with a study idea

Ends after having assessed and evaluated study feasibility

Concept Protocol
Concept Statistics
Concept Drug or Device
Development

Starts with confidence that the study is feasible

Ends after having received ethics and regulatory approval

Development Protocol
Development Statistics
Development Drug or Device
Set-Up

Starts with ethics and regulatory approval

Ends after successful study initiation

Set-Up Protocol
Set-Up Ethics and Laws
Set-Up Statistics
Set-Up Quality and Risk
Set-Up Drug or Device
Conduct

Starts with participant recruitment

Ends after the last participant has completed the last study visit

Conduct Protocol
Conduct Statistics
Conduct Drug or Device
Completion

Starts with last study visit completed

Ends after study publication and archiving

Completion Protocol
Completion Statistics
Completion Drug or Device
Current Path (click to copy): Completion ↦ Management ↦ Archiving ↦ Storage

Please note: the Easy-GCS tool is currently under construction.