Checklist · QualityUpdated October 14, 2026

EDC vendor audit checklist: what a sponsor should examine

A questionnaire tells you what a vendor says. An audit tests whether it is true. This checklist covers scope, the documents to request, questions by area, red flags and how to grade findings, for a sponsor, QA lead or small team auditing an EDC supplier.

  • Scope and risk-based depth
  • Documents to request
  • Findings and follow-up

Free sandbox · No credit card · 21 CFR Part 11 aligned

Audit scope by vendor risk · demo
Desk reviewRemote sessionOn-site
Quality management system
Software validation and change control
Security and access management
Audit trail and data integrity
Support, training and incident handling
Exit, export and data return
Illustrative. Choose depth by what the system does for your study and what the vendor has already shown you.

How this differs from a questionnaire

  • An audit tests evidence. You read records, watch the system used and trace a change from request to release. A questionnaire only collects statements.
  • Depth follows risk. A system that holds your primary endpoint data and consent deserves more scrutiny than a short survey tool. Scope the audit by what could go wrong for participants and data integrity.
  • You stay responsible. Under GCP the sponsor remains responsible for activities it outsources, so oversight of the vendor is part of your quality system. Check the current ICH E6 and local text for the wording.
  • Ask for documents, not adjectives. "Validated" and "secure" mean little until you see the validation summary and the access review.
  • Do not accept claims that are not shown. If a certification or audit report is not offered, record that fact. The absence is the finding.

Purpose

What a vendor audit is for, and where it sits in the buying process

The buying process usually runs in stages. You write requirements and compare options (see the EDC buyer scorecard and the RFP template), you send a security questionnaire, you test the product, and for any system that will hold regulated data you qualify the vendor. An audit is the strongest form of qualification. It can be a document review, a remote session, or a visit.

The regulatory background points the same way. Computerised systems used in clinical trials are expected to be fit for purpose and validated, audit trails are expected to be reliable and reviewable, and sponsors are expected to oversee service providers. The EMA guideline on computerised systems and electronic data in clinical trials, ICH E6 and the FDA Q&A on electronic systems, records and signatures (final October 2024) all discuss these themes. Summaries are in our guides to the EMA computerised systems guideline and computer system validation. Always read the primary text for the wording your inspectors will use.

Small sponsors often assume audits are only for large pharma. In practice a proportionate audit is feasible for anyone: a two-hour remote session with a prepared checklist, a document request list and a short report can be enough for a low-complexity study, and it gives you something concrete to show an inspector.

Process

Run the audit in six steps

  1. 1

    Define scope and risk

    List what the system will do in your study: data entry, consent, randomization, ePRO, safety, exports. Decide depth from that, not from the vendor's size.

  2. 2

    Send the document request

    Ask for items from the table below at least a week ahead, with a due date, so the session is spent on questions and not on finding files.

  3. 3

    Review documents before the session

    Mark what is missing, outdated or inconsistent. Prepare questions from the gaps.

  4. 4

    Hold the session

    Walk through the checklist, ask for demonstrations, and trace one change and one user's access from start to finish. Take notes against evidence seen.

  5. 5

    Grade the findings

    Use a simple scale (critical, major, minor, observation). State the evidence and the requirement each finding refers to.

  6. 6

    Agree actions and follow up

    Ask the vendor for corrective and preventive actions with dates. Decide whether the vendor is approved, approved with conditions or not approved, and set a re-audit interval.

Document request

Documents to request before the audit

Not every vendor will have every item. Record what exists and what does not.

AreaDocument or evidenceWhat you are looking for
QualityQuality manual or SOP index, training records for relevant staffWritten procedures for development, release, support and incident handling, and evidence staff are trained
ValidationValidation plan and summary for the release you will use; test recordsRisk-based testing, traceability from requirement to test, and sign-off
Change controlChange log for the last 6 to 12 months, release notes, rollback procedureChanges assessed, tested, approved and communicated before release
SecuritySecurity policy, access control description, hosting details, encryption description, incident processControls that match what is claimed, and a defined route for reporting a vulnerability
Data integrityAudit trail description and sample export; delete and edit behaviourAppend-only history with user, time, old and new value and reason; how deletes are handled
ContinuityBackup and recovery description, last restore test, outage historyDefined recovery objectives and evidence they were tested
SubcontractorsList of subprocessors and hosting providers, data locationWho touches your data, where, and under what terms
SupportSupport hours, escalation, training materials, documentationResponse times, user guides, and training that matches your roles
ExitExport formats, data return process, deletion process and certificateYou can leave with complete data, a data dictionary and the audit history
RegulatoryInspection history relevant to the product, customer audit summaries where shareableWhether other sponsors or regulators have examined the system

Where something is not available, ask the vendor to say so in writing. That answer is audit evidence.

Questions · system and data

Software, validation and data integrity

How is each release tested and approved?

Ask to see the last release record: requirements, tests, approval, release date and who signed.

Can you show me the audit trail for one changed value?

Look for user, timestamp, old value, new value and reason, and ask whether the trail can be edited by anyone.

What happens when a user deletes data?

Ask whether deletes are hard or soft and where the removed value can still be seen.

How are electronic signatures bound to records?

Identity checks, signature meaning, and what happens if the record changes after signing.

How is access controlled by role?

Demonstrate a restricted role; confirm blinded users cannot see treatment-arm values, in the interface and in exports.

What is the process for fixing a defect found after release?

Look for severity rules, hotfix controls and customer communication.

What does the vendor test that you must still test?

Clarify the shared responsibility for validation; your UAT of your configuration remains yours.

Questions · security and operations

Security, continuity, support and exit

Where is data hosted and who are the subprocessors?

Region, provider, and whether you can choose the region. Ask for the list in writing.

How is data encrypted?

At rest and in transit; ask for the standard, not just the word "encrypted".

How do staff sign in?

Two-factor options, session timeout, password policy and how accounts are removed.

How are vulnerabilities found and reported?

Review practices, a disclosure policy and response targets. Be precise about what has and has not been done, such as which reviews and by whom.

How are backups taken and restored?

Frequency, retention, last restore test and recovery targets.

What is the incident process and notification time?

Who is told, how, and within how long. Compare with your contract and data protection obligations.

What is the exit plan?

Export formats, time to return data, deletion on request and written confirmation. See data ownership and portability.

Audit the real product, not only the paperwork

Build a study in the free Capture sandbox, enter test data, change a value and open the audit trail export. A hands-on look makes your document review sharper. No credit card, no time limit.

Inspect the product free

Findings

Grading findings and deciding

GradeMeaningExampleTypical response
CriticalRisk to participant safety, data integrity or regulatory complianceAudit trail can be edited by an administrator without a recordDo not use until fixed and verified
MajorSignificant gap in a required controlNo tested restore of backupsCorrective action with a date; approval conditional
MinorIsolated lapse, low riskTraining record missing for one staff memberFix at the next review
ObservationImprovement suggestionRelease notes hard to findVendor considers; no formal action

Use the scale in your own SOP if you have one. Record the evidence for every finding.

Warning signs

Red flags worth recording

Documents are promised, not provided

If the validation summary or the change log never arrives, treat it as a missing control, not a scheduling problem.

The audit trail can be edited

Any route that lets an administrator change history without leaving a record is incompatible with data integrity expectations.

Claims that cannot be tied to evidence

A certification, report or test named in marketing but not shown on request. Record that the claim was not supported.

No answer on exit

Vague statements about data return, formats or deletion are a commercial and regulatory risk.

Shared logins and unclear roles

Anything that makes it impossible to attribute an action to a person.

Everything is "on the roadmap"

Future features are not controls. Audit what exists today.

Auditing Capture

What Capture states, and what to ask for

If you are auditing Capture.Study, begin with what the public Security page states and then verify it in the sandbox. As documented there, staff can turn on two-factor authentication with any authenticator app, sessions end after inactivity with a countdown warning, and data is encrypted at rest and in transit. The audit trail is written by database triggers, one row per changed field, is append-only (the database blocks update, delete and truncate on audit rows) and carries a SHA-256 hash chained to the previous row per study. Clinical data is soft-deleted only, and blinded roles never receive treatment-arm values, enforced by masked database views and row-level security. Data is hosted in the EU (Frankfurt) or the USA (N. Virginia). We review the application against the OWASP Top 10, and there is a published vulnerability disclosure policy.

This page does not state that Capture holds a security certification, an independent penetration test or a third-party audit report, and you should not assume one. If your quality system requires specific documents, ask for them in writing during your audit and record the answer. For enterprise customers, Capture provides documentation to support sponsor validation and UAT; ask what that contains for your release. Capture provides 21 CFR Part 11-aligned controls, and validated use is a shared responsibility with the sponsor.

You can also use the product itself as audit evidence. Create a study, change a value with a reason, export the audit trail and check the fields. Try to delete a record and see what remains. Log in as a blinded role and compare views and exports. These hands-on checks take under an hour and are more convincing than a statement. See the audit trail software page and the inspector export page for what the trail contains.

FAQ

Questions teams ask before they switch

Something not covered here? Ask us directly.

Do small sponsors need to audit an EDC vendor?

Sponsors remain responsible for outsourced activities, so some form of oversight is expected. It can be proportionate: a document review and a remote session for a low-complexity study, more depth when the system holds critical data. Follow your own quality system and regulator expectations.

What is the difference between a vendor audit and a security questionnaire?

A questionnaire collects statements. An audit examines evidence such as validation records, change logs and the audit trail in use, and ends with graded findings and actions.

How often should an EDC vendor be re-audited?

Set the interval by risk, for example before first use, after major changes and at a regular interval such as every one to three years. Document the rationale.

What should I do if the vendor will not share a document?

Ask for the reason in writing, look for an equivalent (a summary or a controlled remote view) and record the gap as a finding. Decide whether the risk is acceptable.

Does Capture hold SOC 2 or ISO 27001 certification?

This page makes no such claim. The Security page lists the controls that exist. If your audit requires certificates or reports, ask for them in writing and record the response.

Can I audit Capture hands-on?

Yes. The sandbox has every feature with no credit card and no time limit. Create a study, change a value, export the audit trail and test roles. Enterprise customers can ask about validation documentation.

Is this legal or regulatory advice?

No. It is a general checklist. Use your own SOPs and read the applicable guidelines.

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