FDA Inspection Decision Scenario

Who Authorized the Data Integrity Exception?

“Who made the determination that this data integrity exception did not compromise the reliability of your records?”

21 CFR Part 11 · FDA Data Integrity Guidance 2018

Why this becomes difficult to defend

The decision exists. The basis for it may not be retrievable as one record.

The investigator has identified an audit trail exception in your electronic records. An investigation was opened and closed. The investigator asks who authorized the conclusion.

The data integrity investigation documents what was found and the corrective action taken. It does not document who made the formal determination that the exception did not compromise data reliability — or that this determination was an authorization event.

What must be retrievable

The reviewer needs more than the final outcome.

  • Named individual accountable for the data integrity determination
  • Scope of records reviewed during the assessment
  • Regulatory standard applied to the reliability determination
  • Authorization timestamp for the exception acceptance
  • Reasoning for why the exception did not compromise GxP data reliability

Relevant proof

See how the record connects evidence, judgment, risk, and authorization.

A completed ComplianceWorxs record shows the reasoning layer that is usually hardest to reconstruct after the decision has been made.

EvidenceWhat was known JudgmentHow it was evaluated RiskWhat was weighed AuthorizationWho decided and why

When this is your active decision

Preserve the reasoning before the context disappears.

Use the completed proof first. When the decision is consequential enough to preserve, create an Inspection Response Record for the actual decision.