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Source Access and Targeted SDV: Resolve Practical Boundaries

Source data verification requires both a justified review scope and workable access. Agree the source location, authorised viewer and privacy arrangements.

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Source data verification requires both a justified review scope and workable access. Agree the source location, authorised viewer and privacy arrangements before promising remote review or a fixed percentage of checks.

Define sources and review scope

Distinguish source data review, which examines processes and context, from verification against transcribed values. Identify the authoritative source for critical assessments, including electronic health records and external reports. Do not assume a printed extract contains all relevant history.

Test eligibility evidence access

For an eligibility laboratory result, establish how the reviewer sees collection time, result version and investigator assessment. If access is restricted, record the limitation and agree a suitable alternative. Avoid routine copying of identifiable clinical records into sponsor systems.

Source access checks

  • Confirm named access, permitted functions and expiry arrangements.
  • Document the chosen critical data checks and rationale.
  • Track unavailable records and unresolved discrepancies to disposition.

Record review limitations

Accept the access method after a test user retrieves the required evidence within the approved permissions. Review whether the method remains suitable after hospital system or workflow changes. Record what was actually reviewed so later readers understand the scope and its limits. If remote access fails, record the stopping point and unseen records so a completed visit status does not conceal unfinished source review.

Frequently asked questions

Can a site password be shared with a monitor?
Use authorised individual access arrangements rather than credentials borrowed from site staff.
Is one SDV percentage suitable for every study?
Determine scope from the protocol, critical data and risk assessment; a universal percentage is uninformative.

Sources

  1. FDA — Risk-based monitoring questions and answers, April 2023
  2. EMA — Computerised systems and electronic data in clinical trials