Where to start: CSV Program Overview

add alt text here

Record Type Document
Policy Computer System Validation Policy
ERES Policy
Procedure Computer System Validation Procedure
Work Instruction Validation Testing WI
Validation Impact Assessment WI
Business System Impact Assessment WI
System Periodic Review Work Instruction

Veeva Systems Inc. provides software-as-a-service (SaaS) to customers in the life sciences. Veeva deploys and maintains software solutions that are designed to meet the strict requirements of the life sciences regulated market (i.e., GxP regulations). Our SaaS applications must be designed, tested, deployed and maintained in accordance with regulatory expectations (i.e., directives, regulations, standards and guidance). While regulatory agencies are clear that it is the ultimate responsibility of the end-user (customer, sponsor) to document that Computerized Systems used in the conduct of GxPs are fit for use, in a SaaS deployment, vendors such as Veeva provide much of the documented evidence necessary to demonstrate that such systems can align with the regulatory context of use. This documentation ranges from design verification, infrastructure qualification, and validation functional testing deliverables.

Shared Responsibility Model

Index of CSV Deliverables

CSV Deliverables Available in ComplianceDocs? Description of CSV Deliverable
System Description Yes The system description is a concise document that defines the application at a high level and provides flow and/or system diagrams that help illustrate the application boundaries. Application modules are listed and described
Business Requirements Definition Yes A BRD defines the functions and features of the application from a system and/or user perspective. The document defines “what” the system does (system behaviour and capabilities).
Validation Project Plan Yes A VPP outlines the approach, method, and scope of a validation effort for a General Release (GR).
Validation Impact Analysis Yes A detailed impact assessment is conducted for each release at the development ticket level, to evaluate the criticality of the corresponding product enhancement to GxPs, core functionality, and data integrity.
Installation / Operation Qualification Protocol Yes The IOQ Protocol is a detailed “test plan” that documents, in the form of a “test log,” all of the test scripts (for enhancements and defects) that will be executed for that general release. In addition, the IOQ protocol details the test environment configuration, testing approach and assumptions for that release.
IQ Test Scripts Yes (Audit Only) An IQ Test Script is a self-contained set of test setup, test instructions, and acceptance criteria to demonstrate that a component (infrastructure) is installed and configured in accordance with specifications. An IQ Test Script may also record preconditions (training, configuration, process controls) that need to be in place in order to initiate functional / OQ testing.
OQ Test Scripts Yes An OQ Test Script is a self-contained set of test setup, test instructions, and acceptance criteria to demonstrate that a particular test objective has been achieved. An OQ Test Script Test confirms that operability or functionality of a product requirement, and are traced to the requirements.
Test Incident Yes A TI records observed deviations from test script instructions or criteria vs. system behavior.
Infrastructure Specification No The Infrastructure Specification lists the critical, production infrastructure hardware and software components, as well as minimum HW/SW requirements (e.g., CPU, Memory) to meet performance and operational expectations.
HW / SW Installation Verification No The installation verification of instance/network services, and operating system/utility software is performed by Veeva. Instance Provisioning records the critical to quality components, and the hardening process implemented is recorded in a pre-approved template.
Requirements Trace Matrix Yes The RTM lists all of the requirements defined in the BRD document(s), in order to trace these to corresponding test cases
Validation Summary Report Yes The VSR summarizes all activities associated with the release, starting with the Validation Project Plan and including results of testing defined in the IOQ Protocol. Test results for each executed scripts as well as any test incident encountered are summarized in the VSR. The VSR is a quality gate for GxP production deployments and attests to the validated state of the release.
System Release Memo Yes Optional: An SRM may be issued to document the quality review and release-ability of the code to a production environment, when the VSR is not yet complete.

Relevant Compliance Assessments

FDA 21 CFR Part 11 assessment

EU Annex 11 assessment

Japan ERES assessment

Detailed ERES trace asessment

Useful Knowledge Articles

SaaS Shared Responsibility

Computer Sytsem Compliance Deconstructed

Philosophy Regarding Validation of Business Software

Vault Validation Tips and Tricks

Product Rebaseline Revisited

Validation Defined