One primary objective of the Clinical Trial Regulation (CTR) is to increase transparency and availability of information of clinical trials and their results. Regulation EMA (EU) 536/2014, known as CTR, implemented in early 2022, includes strict expectations for the simultaneous publishing of “public” and “non-public” documents within the CTIS portal. Further, for “public” version documents, the CTR also requires protection of personal data and Commercially Confidential Information (CCI) through adherence to GDPR and the regulation’s own guidance. This has resulted in new expectations for Transparency teams to consistently anonymize all pertinent documents throughout the study lifecycle prior to posting in the CTIS.
For more Information about the CTR and CTIS:
European Medicines Agency (EMA) Clinical Trial Regulation (CTR) Overview
European Medicines Agency (EMA) Clinical Trials Information System (CTIS) Overview
First implemented in 2016, EMA Policy 0070 seeks to enable the wider scientific community to make use of detailed clinical data to develop new knowledge in the interest of public health. The scope of the policy relates to clinical data, composed of clinical reports and individual patient data (IPD), submitted under the centralized marketing authorization. This Policy’s guidance includes detailed expectations for anonymization and protection of personal data and Commercially Confidential Information (CCI). With the anticipated restart of EMA Policy 0070, study sponsors should implement a quantitative data analysis methodology.
The FDA, as outlined in 42 CFR Part 11, indicates that the Study Protocol and Statistical Analysis Plan must be shared via clinicaltrials.gov. The aim of the rule is to help patients find trials for which they might be eligible, enhance the design of clinical trials and prevent duplication of unsuccessful or unsafe trials, improve the evidence base that informs clinical care, increase the efficiency of drug and device development processes, improve clinical research practice, and build public trust in clinical research. The rule goes on to state that the responsible party (study sponsor) may redact names, addresses, and other personally identifiable information, as well as any trade secret and/or confidential commercial information prior to disclosure on clinicaltrials.gov.
Through close partnerships with our customers, over forty (40) regulatory disclosure submissions, anonymization of over 1 million clinical document pages and thousands of datasets, RLS can help your organization maintain pace with the ever changing regulatory landscape.
Whether you are a growing biotech about to embark on your first transparency initiative, or a mid-sized or large Pharma transitioning from qualitative to quantitative anonymization processes or simply seeking confirmation of your processes and approach, RLS can help.
Through sharing our regulatory experiences, implementation of RLS Protect and acting as an extension of our customer’s own teams, RLS will help you achieve your transparency needs.
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