GxP / Guide 1

What GxP means for IT

The GxP family, predicate rules, the regulations and guidance that matter for computer systems, ALCOA+, and who is responsible for what in the cloud.

GxP is shorthand for the "good practice" rules that govern how medicines, medical devices, biologics and other regulated products are researched, made, tested, stored and monitored. For IT, it means one thing: if a system creates, changes, stores or reports data that a regulator relies on to judge product quality or patient safety, you have to show that the system does what it's meant to, that the data can be trusted, and that you can prove both years later. These notes cover how that works on Azure, AWS and SharePoint.

A note before you start: this is practical guidance from running GxP infrastructure, not legal or regulatory advice. Your quality unit, your procedures and your regulators decide what applies to your systems.

The GxP family

PracticeCoversTypical systems
GMP: Good Manufacturing PracticeMaking and releasing productERP batch records, MES, LIMS, QMS, building management and environmental monitoring
GLP: Good Laboratory PracticeNon-clinical safety studiesStudy management, instrument data systems, archives
GCP: Good Clinical PracticeClinical trialsEDC, eTMF, CTMS, IRT, ePRO
GDP: Good Distribution PracticeStorage and transportWarehouse management, temperature monitoring
GVP: Good Pharmacovigilance PracticeSafety monitoring after approvalSafety databases, case intake

Medical device companies also work under design controls and a quality management system (in the US, the QMSR, which aligned 21 CFR 820 with ISO 13485 from 2 February 2026).

Predicate rules come first

The predicate rules are the underlying regulations that say which records you must keep: for example 21 CFR 211 for US drug manufacturing, 21 CFR 58 for GLP, or EU GMP Chapter 4 for documentation. The computer system rules (Part 11 and Annex 11) only apply because a predicate rule requires the record in the first place. So the first question for any system is always: which regulated records does it create or hold, and under which rule? That answer decides whether the system is GxP-relevant and how much control it needs.

The rules for computer systems

DocumentFromWhat it's for
21 CFR Part 11US FDA, 1997Electronic records and electronic signatures. Read with FDA's 2003 Scope and Application guidance, which narrowed how it's enforced.
EU GMP Annex 11European Commission, 2011Computerised systems in GMP. A much longer revision was published as a draft in July 2025 (consultation closed October 2025), alongside a revised Chapter 4 and a new Annex 22 on AI. Check EudraLex Volume 4 for the current status before you rely on either version.
Computer Software Assurance (CSA)US FDA, final September 2025Risk-based assurance for production and quality system software. Replaces section 6 of the 2002 General Principles of Software Validation.
Part 11 in clinical investigations Q&AUS FDA, final October 2024How Part 11 applies to clinical trial systems, including cloud and IT service providers.
ISPE GAMP 5, second editionIndustry, 2022The standard industry approach to computerized system validation, updated for critical thinking, agile, cloud and CSA.
Data integrity guidanceMHRA (2018), PIC/S PI 041-1 (2021), WHOWhat inspectors expect for data integrity across the whole data life cycle.
ICH E6(R3)ICH, 2025Good clinical practice, including computerised systems used in trials.

Guide 2 goes through Part 11 and Annex 11 requirement by requirement, and Guide 3 covers validation.

ALCOA+: what trustworthy data means

Inspectors judge data against ALCOA+. It's the most useful checklist you can give an IT team, because every item maps to a technical control:

PrincipleMeaningWhere IT comes in
AttributableYou can tell who did it, and whenUnique named accounts, no shared logins, audit trails
LegibleReadable for the whole retention periodFormats and viewers that still work in 10 or 25 years
ContemporaneousRecorded when it happenedTrusted time sources, time-stamped entries
OriginalThe first record, or a certified true copyControls on copies, exports and migrations
AccurateCorrect and free from errorsValidated interfaces, input checks, checksums
CompleteNothing missing, including repeats and changesAudit trails that can't be turned off; no silent deletes
ConsistentSame sequence and time stamps across systemsTime synchronization, controlled workflows
EnduringLasts for the retention periodBackups, immutable storage, archiving
AvailableCan be retrieved for review and inspectionSearchable archives, tested restores

What's in scope, and how much control

Not every system in a life sciences company is GxP, and treating everything as GxP is expensive and dilutes attention. Most companies classify each system with a short assessment:

  1. Is it GxP-relevant? Does it create, change, hold or report records required by a predicate rule, or does it support a GxP process (release, deviation, complaint, training, stability)?
  2. How much risk? What happens to product quality, patient safety or data integrity if it fails or gives a wrong result? This drives the depth of validation and the strength of controls.
  3. What kind of software? Infrastructure, standard, configured or custom (the GAMP categories in Guide 3).

Infrastructure under a GxP system (the subscription, VPC, directory, backup, logging) isn't "validated" itself, but it must be qualified and kept under control, because the validated system depends on it. Guide 4 covers that.

In these notes, GxP scope is marked with a tag: GxP = Yes on the Azure subscription or resource group, or on the AWS account and resources. The evidence scripts use the same tag, so the scope you declare is the scope you report on.

Shared responsibility in the cloud

There is no such thing as a "GxP-certified" or "Part 11-certified" cloud. Microsoft and AWS both say so directly. What they provide is a platform with independent audits (ISO 9001, ISO 27001, SOC 1 and SOC 2) and GxP guidance documents, and you remain responsible for the regulated system and its data:

LayerCloud providerYou
Data centers, hardware, hypervisorOperates, secures, auditsAssess the provider as a supplier and review its audit reports
Platform services (PaaS)Operates the serviceConfigure it, control changes, keep logs and backups
Accounts, networks, identitiesProvides the toolsDesign, qualify and control them
Operating systems and applications—Validate, patch, back up, review access
GxP data and records—Integrity, retention, audit trails, availability

For SaaS (for example a hosted LIMS or QMS), the vendor takes on more of the stack, but you still own the validation of your intended use, the supplier assessment and the quality agreement.

How these notes are organised

  • Regulations and validation (Guides 2 and 3): what the rules ask for, and how to show you meet them without drowning in paperwork.
  • Platforms (Guide 4): qualifying Azure and AWS landing zones.
  • Controls (Guides 5 to 8): audit trails, access control, change control, and backup and disaster recovery. These are the controls inspectors test most often, and the ones IT owns.
  • Documents and operations (Guides 9 and 10): SharePoint for controlled documents, periodic review and inspection readiness.

The scripts are all read-only. Each one writes a CSV plus a .sha256 file recording the file's hash, who ran it, when and with which parameters, so the output can go straight into an evidence folder.