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Checklist Plug-and-play starting point CSV / CSA

Checklist: Off-Host Log Store Tamper-Evidence Integrity Verification

A plug-and-play periodic checklist that re-proves the off-host security log store's tamper-evidence (WORM, immutability lock, or hash-chaining) actually still holds, rather than relying on the original installation qualification, with a filled specimen and escalation path.

Document type: Checklist

Read and copy the template below into your own quality system. It is a generic starting point for your own internal use, provided as is, with no warranty; see the Terms and License. Adopting it does not by itself create compliance.

This is a ready-to-use checklist. Replace every <<FILL: ...>> placeholder with your own specifics and route completed copies through your normal periodic review and retention process. A worked filled specimen follows the template. Verify each cited regulation against the current source before you rely on it.

Purpose

Qualifying the off-host security log store at installation proves the tamper-evidence control, write-once/read-many storage, an object-lock retention policy, or hash-chaining, worked on that day. It does not prove the control still works a year later, after a storage migration, a platform upgrade, or a policy change. This checklist re-tests the control on a defined schedule so a silently degraded protection is caught before, not after, the evidence is needed.

Scope

FieldEntry
Log store / platform<<FILL>>
Tamper-evidence mechanism in use<<FILL: WORM, object-lock, hash-chaining, or combination>>
GxP systems whose security events this store protects<<FILL>>
Verification frequency<<FILL: e.g. annually, or more often for High tier>>
Performed by<<FILL: role, independent of the team that administers the log store>>

Verification checklist

#ItemPass / Fail / NA
1Select a test event already committed to the store (or a designated test partition, if the platform supports one, to avoid touching production evidence)<<FILL>>
2Attempt a controlled deletion of the test event using credentials that would be available to a GxP host administrator<<FILL>>
3Confirm the deletion attempt was blocked outright, or produced a detectable integrity failure (a logged denial, a hash mismatch); a silent success is an automatic Fail<<FILL>>
4Attempt a controlled alteration of the test event’s content<<FILL>>
5Confirm the alteration attempt was blocked or detected the same way<<FILL>>
6Independently recompute the stored hash or chain value for a sample of archived events (minimum <<FILL: sample size>>)<<FILL>>
7Confirm the recomputed value matches the value recorded at ingestion for every sampled event<<FILL>>
8Confirm the object-lock, WORM, or retention-lock setting is currently active on the store (not just documented as configured at go-live)<<FILL>>
9Confirm the active retention period is still at or beyond the retention period of the GxP records this store protects<<FILL>>
10Confirm no storage-tier migration, platform upgrade, or configuration change since the last verification has altered the tamper-evidence mechanism without a documented change-control and re-verification<<FILL>>
11Confirm the administrators of the underlying storage platform (if a different team from the log-store owner) do not hold rights that bypass the tamper-evidence control<<FILL>>

Escalation

Any Fail is a data integrity finding, not a maintenance ticket. Raise a deviation the same day per <<FILL: SOP-ID for deviations>>, notify the system owners of every GxP system this store protects, and treat the period since the last successful verification as a window of unproven tamper-evidence until a root cause and corrective action are documented. Do not wait for the next scheduled verification to re-test after a Fail; re-test immediately after the fix.

Acceptance criteria

The verification is acceptable when every item carries a documented basis, any Fail escalates same-day, and an independent reviewer signs the record.

References

21 CFR 11.10(e) (audit trails shall not obscure previously recorded information, applied to the log store). EU GMP Annex 11, clause 9 (audit trails) and clause 12 (security). MHRA GxP Data Integrity Guidance and Definitions; PIC/S PI 041.

Confirm the current version and clause numbers of each reference before issue.


Filled specimen

FieldEntry
Log store / platformCentral security log archive, object storage with retention lock
Tamper-evidence mechanism in useObject-lock (compliance mode) plus per-batch hash chaining
GxP systems protectedCDS (HPLC/UPLC), LIMS, MES
Verification frequencyAnnual (High tier)
Performed byM. Osei, IT Security, independent of the log-store administration team
#ItemResult
1Test event selectedTest event from the designated test partition, dated 03 Sept 2026
2Deletion attempt madeAttempted using a credential equivalent to a CDS host administrator
3Deletion blocked or detectedPass; API returned an access-denied response, logged with a denial event
4Alteration attempt madeAttempted a metadata field edit on the same test event
5Alteration blocked or detectedPass; object-lock prevented the write
6Hash recompute, sample50 archived events sampled across the retention period
7Recomputed values matchedPass, 50 of 50 matched
8Object-lock setting currently activePass, confirmed via platform console and exported configuration report
9Retention period still sufficientPass, lock set to 10 years; longest-retention record it protects requires 7
10No unreviewed change since last verificationFail; a storage-tier migration in May 2026 moved the archive to a new storage class, and the migration change record did not include a re-verification step
11Storage-platform administrators cannot bypass the controlPass, confirmed via access-control review; storage admins hold no object-lock override permission

Disposition: Item 10 scored Fail. Deviation DEV-2026-0311 opened the same day. Root cause: the change-control procedure for infrastructure migrations did not include a tamper-evidence re-verification step as a mandatory checklist item. Corrective action: items 1-9 of this checklist were re-performed immediately following the finding (all passed, confirming no actual loss of protection occurred), and the infrastructure change-control procedure was updated to require this checklist’s completion as a closure condition for any future migration touching the log store.

Common inspection findings this checklist prevents

  • Tamper-evidence proven once at installation qualification and never re-tested, so a later degradation (a lapsed retention lock, a stopped hashing job) goes undetected until evidence is actually needed and is not there.
  • A storage migration or platform upgrade that silently carries forward a changed configuration, with no re-verification built into the change-control process.
  • A log store’s retention setting correct at go-live but shortened later by a storage administrator with no connection to the GxP system the store protects.
  • No independent party ever actually attempts to break the control; the tamper-evidence claim rests entirely on vendor documentation or a single historical test.

How to adapt this checklist

  1. Set the verification frequency from the risk tier of the systems the store protects; a High tier store supporting release decisions warrants more than an annual check.
  2. Build the test-partition or test-event mechanism into the log store’s own design so verification never touches real evidentiary records.
  3. Add this checklist’s completion as a mandatory closure condition in your infrastructure change-control procedure for any change touching the log store, the gap the filled specimen above illustrates.
  4. Point the escalation path to your real deviation and CAPA procedures.
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