1. Log the time, date and id of person making an entry into the system (audit trail)
2. Ensure that only authorised persons can access the systems (access levels, data encryption)
3. Support two token signatures (userid and password)
4. Protect and ensure uniqueness of signatures (password database encryption and management)
5. Record and protect against unauthorised access attempts into the system.
When 21 CFR Part 11 was released in 1997, it was hailed as a landmark regulation that finally made electronic records and signatures as valid as paper records and handwritten signatures. It allows the use of electronic record-keeping systems in complying with regulations. Part 11 (also known as "Electronic Records; Electronic Signatures" or ERES) works in tandem with a predicate rule, which refers to any FDA regulation that requires organizations to maintain records.
It is not possible for any vendor to offer a turnkey 'Part 11 compliant system'. Any vendor who makes such a claim is incorrect. Part 11 requires both procedural controls (i.e. notification, training, SOPs, administration) and administrative controls to be put in place by the user in addition to the technical controls that the vendor can offer. At best, the vendor can offer an application containing the required technical requirements of a compliant system.