AI GxP validation for regulated life sciences
Guide

Data Integrity (ALCOA+) Guide

ALCOA+ across GxP systems — with gap assessments, remediation patterns and a monitoring cadence that keeps it from drifting.

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In short

ALCOA+ is the set of attributes regulated data must have to be trusted: Attributable, Legible, Contemporaneous, Original and Accurate, extended with Complete, Consistent, Enduring and Available. It applies to paper and electronic records alike, and to every point where regulated data is created, changed, transferred or archived.

Audit trail
  1. 14:32Signed: Approved for releaseQA Manager
  2. 11:05Changed risk of URS-015Validation lead · Supplier test evidence acceptedMedium → Low
  3. 10:48Edited expected result, OQ-07Validation lead · Lockout after 5 attempts, per URSv3 → v4
  4. 09:12Recorded result, OQ-07Tester · Evidence attachedPassed
Append-only. Entries cannot be edited or deleted.
Who, what, when and whyOn every change
An audit trail an inspector can read: who did what, when, the old and new value and the reason. Entries are append-only and each one is linked to the one before, so a changed or missing entry shows.

The original five

  • 1

    Attributable

    You can tell who created or changed each record and when. Shared logins break this at the first question.

  • 2

    Legible

    Readable and permanent, for people and for systems, throughout the retention period — including after a platform migration.

  • 3

    Contemporaneous

    Recorded as the work happens, not written up afterwards. Timestamps come from the system, not from the user.

  • 4

    Original

    The first capture, or a verified true copy with the verification recorded. For instruments, this usually means the raw data file, not a printout.

  • 5

    Accurate

    Correct and complete, with errors corrected through a controlled process that preserves the original value.

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The plus four

  • 6

    Complete

    All data including repeats, failures and reprocessing. Deleting a failed run and keeping the passing one is the classic integrity failure.

  • 7

    Consistent

    Sequenced correctly, with date and time applied uniformly across systems and time zones.

  • 8

    Enduring

    Survives for the full retention period on durable media, through system replacement.

  • 9

    Available

    Retrievable for review or inspection throughout that period, without heroic effort.

Where integrity actually breaks

In practice, findings cluster around a small number of recurring situations rather than the principles themselves.

  • 10

    Shared or generic accounts

    Eliminated wherever regulated data is created or approved. One account, one person.

  • 11

    Users able to delete or overwrite raw data

    Permissions prevent it. Where a system allows it, the audit trail must capture it and someone must review that.

  • 12

    System clocks unsynchronised

    Clocks synchronised to a controlled source, and users cannot change them.

  • 13

    Audit trail switchable off

    Cannot be disabled by any user role available in production.

  • 14

    Spreadsheets as uncontrolled records

    Any spreadsheet holding regulated data is validated, access-controlled and version-managed, or replaced.

  • 15

    Unreviewed audit trails

    Review is defined, scheduled, performed by someone competent to spot a problem, and recorded.

  • 16

    Testing into compliance

    Repeating a test until it passes, without recording the earlier results, is falsification. Controls must make it impossible rather than discouraged.

The data lifecycle, point by point

Assess integrity where data moves, not only where it lives. Transfers and migrations are where it is most often lost.

  • 17

    Creation and capture

    Instrument interfaces verified, manual entry subject to a second check where critical.

  • 18

    Processing

    Calculations and transformations validated and reproducible, with processing parameters recorded.

  • 19

    Review and approval

    Reviewers see the underlying data and the audit trail, not only the summary.

  • 20

    Transfer between systems

    Checks confirm the data arrived complete and unchanged.

  • 21

    Archive and migration

    Readability preserved across platform changes, with migration verified record by record for critical data.

  • 22

    Destruction

    Only after the retention period, through a controlled, documented process.

How to use this

Data integrity is a culture question before it is a technical one. Most serious breaches happen where people feel unable to report a bad result — controls reduce opportunity, but they do not remove the pressure that creates the motive.

Apply ALCOA+ to paper as rigorously as to electronic records. Hybrid processes, where a printout is signed against an electronic original, are where integrity is most often quietly lost.

This is a working aid, not a regulatory document, and it does not replace your own quality system procedures.

Explore related resources, products and services: GxP Copilot, TraceDraft, validation services, AI transformation.

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Sources

Primary documents referred to on this page, from their official publishers.

FAQ

Common questions

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What does ALCOA+ stand for?

Attributable, Legible, Contemporaneous, Original and Accurate — the original ALCOA attributes — extended with Complete, Consistent, Enduring and Available. Together they define the properties regulated data must have to be considered reliable, and they apply equally to paper and electronic records.

What is the difference between ALCOA and ALCOA+?

ALCOA is the original five attributes: Attributable, Legible, Contemporaneous, Original, Accurate. ALCOA+ adds Complete, Consistent, Enduring and Available, which were introduced to address gaps that became obvious with electronic systems — particularly around retaining all data including failed runs, and keeping it readable for its full retention period.

What are the most common data integrity findings?

Shared or generic user accounts that break attributability, audit trails that are never reviewed, users able to delete or overwrite raw data, unsynchronised or user-changeable system clocks, uncontrolled spreadsheets holding regulated data, and repeating a test until it passes without retaining the earlier results.

Does ALCOA+ apply to paper records?

Yes. The principles are format-independent. Hybrid processes deserve particular attention — where a printout is signed against an electronic original, it must be clear which is the raw data, how the two are linked, and that changes made after the original entry remain visible.

Who is responsible for data integrity?

Everyone who creates, reviews or approves regulated data, with senior management accountable for the culture and the systems that make integrity achievable. Most serious breaches occur where staff feel unable to report an unfavourable result, so governance has to address pressure as well as technical controls.

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