Whitepaper/ Arkivum digital archive solutions for Life Sciences Introduction Arkivum is an established provider of data archiving solutions. Arkivum’s Archive as a Service provides a fully-managed and secure service for long-term data retention with online access and a guarantee of data integrity that’s part of our Service Level Agreement and backed by worldwide insurance. Recognising that many organisations don’t allow their data to go off-site, OSCAR, Arkivum’s On-Site Cloud ARrchive, offers all of the Arkivum shared managed service’s data integrity and management features within a corporate firewall, making it ideal for organisations where confidentiality or regulation requires all information to be stored onsite. The benefits of using Arkivum’s solutions The most common approach to archiving data in corporate environments is to retain data on the same systems where it was first created, e.g. enterprise storage servers. The capacity of these servers then grows to match ever increasing volumes of data and the need to keep ever more of it for compliance or reuse. This approach is expensive, difficult to manage, and can put data at risk; for example through hardware failures or accidental data deletion or modification. Keeping infrequently accessed and static archive data on expensive enterprise storage servers is a luxury in today’s challenging economic climate. The solution is to move data off these systems into Arkivum managed facilities or services which are optimised for archiving. This saves money, saves effort, frees up resources, and reduces risk that data cannot be found or accessed again in the future. But this isn’t the only benefit of using an Arkivum solution. Most organisations underestimate the longterm Total Cost of Ownership of archiving, especially where stringent data retention requirements need to be met. Long-term archiving requires specialist expertise, active data management, the procurement and migration of systems to address obsolescence, and regular auditing to make sure retention metrics are being met. Arkivum has all these in place, including ISO27001 certification and 21 CFR Part 11 enablement. Using one of our solutions isn’t just about storing data - it’s about accessing our expertise and approach, which saves having to develop or maintain this in-house. Specific business and commercial benefits include: • 50% cost savings On enterprise storage (or more) are typically achievable by moving archive data off expensive storage servers and into an Arkivum archive solution, either onsite or using our storage service. We develop Total Cost of Ownership (TCO) models with our clients to illustrate the specific cost advantages in both the short, medium and long term of the Arkivum solution compared to other solutions. • 80% reduction in cost and time for backups It is common for the majority of data on enterprise storage to be infrequently or ever accessed again. Moving it to a dedicated Arkivum archive solution means it doesn’t clog-up nightly or weekly backups, which in turn are both faster and cheaper. • 100% data retrieval When faced with compliance audits or the need to reuse valuable company data. Arkivum guarantees the 100% integrity of all data stored in our service – with no limits on time or volume. Our data protection measures are so extensive that we are backed by worldwide insurance that covers the costs incurred to our customers as a direct result of us losing data Availability of our service is also high at 99.9% and it takes less than 5 minutes to start receiving data back from our service. • 75% reduction in costs of 21CFRpart111 compliance Many companies focus on the initial parts of the data lifecycle (rather than the whole lifecycle costs) for Arkivu m Limited R21 Langley Park Way Chippenham Wiltshire SN15 1GE UK +44 1249 405060 info@arkivum.com @Arkivum Arkivum.com Title Arkivum digital archive solutions for Life Sciences Part no ARK/MKTG/ALL/181 Version 1.1 Date June 2014 Statu s Release 1/7 © Arkivum Ltd 2014 21CFRpart11, e.g. putting proper digital signatures processes in place to ensure authenticity. But the main costs typically are in the long-term where integrity, authenticity, confidentiality and availability need to be delivered over decade retention periods or longer. This is where Arkivum can make a big impact as it has the people, processes and infrastructure already in place to deliver these functions. • 70% reduction in IT power Arkivum’s use of data tape results in a highly energy efficient storage service. Power consumption is less than 10% of ‘spinning disks’ in an enterprise storage server. This results in a low carbon footprint at a time where ‘green IT’ is becoming increasingly important, but also has a major practical benefit on the customer site where power and cooling maybe limited. • 100% known costs Our service and solution is transparent and includes all costs of data retention, including people, equipment, maintenance, upgrades, migrations, ISO27001 audits – the list is extensive! We can offer our service at a fixed cost per TB stored, either PAYG or fixed-term, over a period of many years. This means much more manageable and predictable budgets, with forward planning becoming less of a gamble – and the ability for Arkivum customers to pass on long-term retention costs onto their customers! • 0% vendor lock-in. Our use of data tape allows us to support data escrow for our archive service and external offline copies of data for OSCAR – encrypted in both cases if required. Files are stored in exactly the format you supply then and are easily retrieved from tape using stand-alone tape drives and LTFS open source software - which means you are in no way tied into our service or any proprietary technology. If your business drivers and requirements change, due to mergers, acquisitions or re-sizing, you can easily and quickly migrate from the Arkivum solution if you need to. How does Arkivum support 21CFR11 compliance? Arkivum can be instrumental in helping a company achieve 21CFR11 compliance. Arkivum’s service meets the key requirements of 21CFR11: Integrity, authenticity, confidentiality and the need for availability (ready access). We have designed system from ground up with information security in mind. We have been certified to ISO27001, which includes a detailed risk assessment of the integrity, availability and confidentiality of customer assets in our possession. This all means that Arkivum’s service or OSCAR onsite solution can substantially reduce the cost and effort of meeting compliance. We are very transparent in what we do – you need to know that your data is safe in our hands. We openly share details of our people, processes and infrastructure with both customers and auditors and we are willing to be audited when a customer is itself being 21CFR11 audited. With respect to 21CFRpart11, Arkivum supports retention of documents that are both in-scope and outof-scope2. Our service is classed as an ‘Open System’ and hence controls for open systems apply. The controls for open systems (21CFRpart11 Sec 11.30) include all the controls for closed systems (21CFRpart11 Sec 11.10), so in the table below we show how we address both sets of requirements. Arkivum Limited R21 Langley Park Way Chippenham Wiltshire SN15 1GE UK +44 1249 405060 info@arkivum.com @Arkivum Arkivum.com Title Arkivum digital archive solutions for Life Sciences Part n o ARK/MKTG/ALL/181 Ve rsion 1.1 Date June 2014 S tatus Release 2/7 © Arkivum Ltd 2014 21 CFR part 11 requirement Arkivum approach Sec. 11.10 Controls for closed systems. • Automated and regular integrity checks are performed on of all data and metadata held in the service to confirm integrity. Persons who use closed systems to create, modify, maintain, or transmit electronic records shall employ procedures and controls designed to ensure the authenticity, integrity, and, when appropriate, the confidentiality of electronic records, and to ensure that the signer cannot readily repudiate the signed record as not genuine. Such procedures and controls shall include the following: (a) Validation of systems to ensure accuracy, reliability, consistent intended performance, and the ability to discern invalid or altered records. • Integrity is checked using checksums that have been agreed with customer to ensure that no tampering can occur on any copies of the data without detection. • Multiple copies are held of customer data, so if integrity is lost in one copy (e.g. failure of storage technology) then other copies can be used to replace it with a known good copy. • Checksums and detection of any integrity loss are both fully automated and periodically executed to ensure that data remains unchanged, invalid or altered data is detected, and the archive service is delivered within specified levels of performance. • Arkivum conducts regular tests of our software and systems through fault injection and failure simulation to validate that threats to data integrity, availability and confidentiality are all mitigated and handled correctly. Sec. 11.10 (b) The ability to generate accurate and complete copies of records in both human readable and electronic form suitable for inspection, review, and copying by the agency. Persons should contact the agency if there are any questions regarding the ability of the agency to perform such review and copying of the electronic records. • Arkivum’s service ensures all customer data can be readily accessed in its entirety and in bit-for-bit identical form to the originally submitted data. • Arkivum’s service supports a customer in being able to generate accurate and complete reports for an inspection or review by the United States, Food and Drug Administration (FDA). • High availability and online access to all customer data through file system and web interfaces means that complete record sets can be retrieved and delivered to the FDA when required. Arkivum Limited R21 Langley Park Way Chippenham Wiltshire SN15 1GE UK +44 1249 405060 info@arkivum.com @Arkivum Arkivum.com Title Arkivum digital archive solutions for Life Sciences Part n o ARK/MKTG/ALL/181 Ve rsion 1.1 Date June 2014 S tatus Release 3/7 © Arkivum Ltd 2014 Sec. 11.10 (c) Protection of records to enable their accurate and ready retrieval throughout the records retention period. • Arkivum’s service ensures all customer data can be readily accessed in its entirety and in bit-for-bit identical form to the originally submitted data. • Arkivum’s service supports a customer in being able to generate accurate and complete reports for an inspection or review by the United States, Food and Drug Administration (FDA). • High availability and online access to all customer data through file system and web interfaces means that complete record sets can be retrieved and delivered to the FDA when required. Sec. 11.10 (c) Protection of records to enable their accurate and ready retrieval throughout the records retention period. • Arkivum guarantees data integrity (accuracy) and provides a very high level of availability with fast access (read retrieval). Both are in our Service Level Agreement (SLA) (100% data integrity, 99.9% availability, less than 5 minutes retrieval latency). • Accuracy: checksums are used on all data we store. We cross-check and agree these checksums with the customer to ensure we have correctly received the data. We use the checksums to actively manage data integrity by detecting corrupted data and restoring integrity using the replicas we store for each and every file. Whenever a customer requests a file from the archive, the checksums are used to confirm that it is bit-identical to the original. No files are ever returned without passing this test. • Ready retrieval: Files in the Arkivum service are stored in two separate data centres in online tape libraries. For the OSCAR onsite solution, tape libraries are installed on the customer site. Tape libraries mean that access to files is quick – less than 5 minutes to get to the start of any file and then a very high data rates when getting data back. If files are accessed frequently, then they can be cached on hard drives to provide fast repeated access without needing to pull data from tape or over the network every time Arkivum Limited R21 Langley Park Way Chippenham Wiltshire SN15 1GE UK +44 1249 405060 info@arkivum.com @Arkivum Arkivum.com Title Arkivum digital archive solutions for Life Sciences Part n o ARK/MKTG/ALL/181 Ve rsion 1.1 Date June 2014 S tatus Release 4/7 © Arkivum Ltd 2014 Sec. 11.10 (d) Limiting system access to authorized individuals. • We have a full information security management process in place that covers all aspects of security including people, process, facilities, equipment and software. We are certified to ISO27001 and regularly audited for compliance. • Data storage at our data centres and escrow site uses a range of physical security measures. Each customer’s data is on a dedicated set of tapes, including the escrow copies. • Remote online access to data is only available to the customer that submitted the data. Hardware firewalls are used to tightly control both customer access to and Arkivum management of our service. • Only specific trained and authorised Arkivum staff can administer our storage systems. Sec. 11.10 (e) Use of secure, computer-generated, timestamped audit trails to independently record the date and time of operator entries and actions that create, modify, or delete electronic records. Record changes shall not obscure previously recorded information. Such audit trail documentation shall be retained for a period at least as long as that required for the subject electronic records and shall be available for agency review and copying. • We store a complete record of where every file has come from, what its ownership and permissions are, when it has been retrieved by the customer, when we’ve migrated it to new media, when we’ve checked its integrity, when it went into escrow - and any unauthorised attempts to access the file. This allows assertions to be made that records are secured and haven’t changed. · Records are kept of customer data access as well as any activities within our service that ‘touch’ the data such as integrity checks. These are held in secured log files that are timestamped, digitally signed by Arkivum, replicated for safety and cannot be overwritten. This ensures that a full audit trail is available for all customer data. Arkivum Limited R21 Langley Park Way Chippenham Wiltshire SN15 1GE UK +44 1249 405060 info@arkivum.com @Arkivum Arkivum.com Title Arkivum digital archive solutions for Life Sciences Part n o ARK/MKTG/ALL/181 Ve rsion 1.1 Date June 2014 S tatus Release 5/7 © Arkivum Ltd 2014 Sec. 11.10 (f) Use of operational system checks to enforce permitted sequencing of steps and events, as appropriate. • All data in the Arkivum service is WORM (write once, read many) unless explicitly requested by the customer. Attempts to append/modify/overwrite/delete are all trapped and blocked. • Processes executed by Arkivum staff are tightly governed and can only be executed by nominated individuals, e.g. moving media offsite to escrow, migration of media within our tape libraries, and maintenance and upgrade. • All customer data is stored in fixed locations that are agreed in advance with our customers. We never move customer data to another location without permission first. • Data for each customer is on dedicated tapes. These tapes are only ever handled by trained Arkivum staff, who are responsible for their safekeeping through use of our highly automated data management systems. • We use a barcode and RFID based tape tracking system so we know the exact location of every tape we hold. This is done all the way from blank media arriving into our facilities for QA through to loading tapes in our Data Centre tape libraries and then any secure transfer of externalised tapes to our escrow site. • We record exactly who at Arkivum does each activity and all our staff adhere to tightly defined company policies that embody digital preservation and information security recommended practice. Sec. 11.10 (g) Use of authority checks to ensure that only authorized individuals can use the system, electronically sign a record, access the operation or computer system input or output device, alter a record, or perform the operation at hand. Sec. 11.10 (h) Determination that persons who develop, maintain, or use electronic record/electronic signature systems have the education, training, and experience to perform their assigned tasks. • Arkivum integrates with Active Directory to secure ingest of files into our service and access to files within our service. • Administration actions, e.g. deleting data or specifying the key used to encrypt data, can only be done through a secured administration interface. · Only authorised Arkivum staff can perform actions that have the potential to change or move data, e.g. migrations. • Electronic signatures and use of electronic record systems is a requirement on customer systems. • Our service allows the safe and secure longterm storage of data that has already been signed and exported from these systems. Arkivum Limited R21 Langley Park Way Chippenham Wiltshire SN15 1GE UK +44 1249 405060 info@arkivum.com @Arkivum Arkivum.com Title Arkivum digital archive solutions for Life Sciences Part n o ARK/MKTG/ALL/181 Ve rsion 1.1 Date June 2014 S tatus Release 6/7 © Arkivum Ltd 2014 Sec. 11.10 (i) Use of appropriate controls over systems documentation including: (1) Adequate controls over the distribution of, access to, and use of documentation for system operation and maintenance. (2) Revision and change control procedures to maintain an audit trail that documents timesequenced development and modification of systems documentation. • Arkivum is certified to ISO27001 “Information Security Management System” • ISO27001 This includes Control A12 ‘Information Systems Acquisition, Development and Maintenance’ In this context, information systems are taken to mean the operating systems, infrastructure, business applications, off-the-shelf products, services, and internally developed software and applications. A12 includes software engineering, version control, change management, document management and security of information that describes the design and operation of the system. • As a result, Arkivum has an independently audited approach to controlling access to documentation on our systems and an audit trail of how our systems and associated documentation change over time. Sec. 11.30 Controls for open systems. Additional measures: Persons who use open systems to create, modify, maintain, or transmit electronic records shall employ procedures and controls designed to ensure the authenticity, integrity, and, as appropriate, the confidentiality of electronic records from the point of their creation to the point of their receipt. Such procedures and controls shall include those identified in 11.10, as appropriate, and additional measures such as document encryption and use of appropriate digital signature standards to ensure, as necessary under the circumstances, record authenticity, integrity, and confidentiality. • All data held in our service is encrypted using AES256 to ensure confidentiality. Encryption happens on the customer site before data leaves the customer network. The keys for decryption never leave the customer network so no one else can read the data, including Arkivum. • There is an option of digitally signed confirmation of receipt of data by Arkivum for non-repudiation (chain of custody). • Industry standard checksums (e.g. MD5) are generated for all data received into our service. The checksums can be exchanged with the customer to verify correct receipt of data to ensure an unbroken data integrity chain. Arkivum Limited R21 Langley Park Way Chippenham Wiltshire SN15 1GE UK +44 1249 405060 info@arkivum.com @Arkivum Arkivum.com Title Arkivum digital archive solutions for Life Sciences Part n o ARK/MKTG/ALL/181 Ve rsion 1.1 Date June 2014 S tatus Release 7/7 © Arkivum Ltd 2014