Guides · Everyone

How to lock a study database

A lock closes a study's records to change, and a reviewer proves nothing moved by recomputing its fingerprint and finding no audit entry after it.

Published October 30, 2026 · sources checked October 30, 2026. Signalment is a data system; the protocol, the ethics review, the consent and any filing stay with the sponsor and the investigators.

A database lock is the moment a study's records stop changing. Before it, the last forms come in, the monitor's questions are answered, corrections are made with their reasons and the investigator signs off. At the lock, the data become the fixed set that the analysis and the final study report rest on. A reviewer proves nothing changed after it with two checks: the audit trail shows no entry dated after the lock, and a fingerprint of the locked data, a short code computed from every value and recorded at the lock, comes out the same when the reviewer recomputes it from the copy in hand. Change one value and the code changes.

What the rules ask

GL9 never uses the words "database lock". FDA's Center for Veterinary Medicine names it in Guidance #197, Documenting Electronic Data Files and Statistical Analysis Programs (November 2020). Section III.B.2 treats the audit trail of an electronic data capture (EDC) system as part of the raw data: the original value, every change, who made it, when, the reason, "and the date when the database was locked". Its sample audit-trail file has a lockdate column. Section III.B.3.b adds that "Submitted data files should be unmodified after export from the database"; when a file is changed for analysis, the sponsor describes the change and supplies the program that made it.

Guidance #287, Raw Data for Safety and Effectiveness Studies (June 2025), section III, says "The audit trail should also be submitted if raw data were collected by an electronic data capture system." Section IV asks the sponsor to describe how the data were collected, "including a record of all changes to the raw data", from the EDC files to the completed statistical analyses.

Guidance #85 (VICH GL9), the good clinical practice standard for veterinary studies, defines the final study report as one written "after the collection of all raw data is complete" (1.13). It keeps every change to electronic data in an audit trail (8.3.6), stores study documentation protected from "deterioration, destruction, tampering or vandalism" (8.4.1), and makes any correction to the final report a signed, dated amendment with its reason (7.4).

21 CFR Part 11 applies to records kept electronically under an FDA records requirement or submitted to FDA (11.1(b)). Section 11.10 asks for validation that includes "the ability to discern invalid or altered records" (a), accurate and complete copies in human-readable and electronic form (b), protection of records through the retention period (c), and secure, time-stamped audit trails whose changes "shall not obscure previously recorded information", kept as long as the records (e). Section 11.70 links each signature to its record so it cannot be "excised, copied, or otherwise transferred". FDA's October 2024 questions-and-answers guidance on electronic systems, which lists CVM among its issuing centers, says audit trails "should be protected from modification and from being disabled" (Q12), and that sponsor inspections look at the procedures that keep the records needed to reconstruct a study from being "altered in value or meaning" (Q8).

How a reviewer checks a lock

A monitor, an auditor or an FDA reviewer holding the export can run these checks without the system that produced it.

If all five hold, the data the report rests on are the data that were locked.

Steps to a lock

  1. Write the lock into the protocol or the data management plan before the first animal enrolls: who may lock, and what must be true first. GL9 6.3.18 asks the protocol to set out how raw data are recorded, processed, handled and retained.
  2. Bring in the last data: every visit, every owner diary entry, every laboratory panel, every end-of-study form.
  3. Close the monitor's queries. List any left open, with the reason.
  4. Reconcile adverse events, concomitant medications and deviations. GL9 3.2.5 asks for each deviation in a signed and dated statement.
  5. Have the investigator sign off the records.
  6. Lock. Record the date, the time, who locked and the fingerprint.
  7. Export at once: one file per form, a data dictionary and the audit trail with the lock date.
  8. In a blinded study, open the allocation for analysis only after the lock, so the lock date also shows the data were fixed before anyone saw the arms. GL9 3.2.18 lets a treatment code be broken only as the protocol says and with the sponsor's knowledge and consent.
  9. If a value must change after the lock, record the change, the reason and the date on the audit trail, and lock again with a new fingerprint. Never change a locked value silently.

What changes with the study design

What stays with the sponsor and the investigator

The lock is a decision people make. When to lock, what the protocol says about it, whether a change after the lock is justified, the ethics review, the consent content, the INAD file, any submission and every adverse event report belong to the sponsor and the investigator. GL9 4.3.1 leaves the "ultimate responsibility for the quality and integrity of the study data" with the sponsor, and the 2024 guidance (Q17) keeps sponsors responsible for any obligation not lawfully transferred to an IT service provider. A data system can make a lock hard to break and easy to check. It cannot decide that the data are ready.

Signalment and the lock

Signalment is a data system. A study in it closes with a database lock that carries a fingerprint. The audit trail is append-only and hash-chained, and it is exported with the fingerprints in a JSON bundle next to CSV files per form and a data dictionary, so a monitor can verify the chain offline, on their own laptop. Signatures re-check the signer's password and bind to the hash of what was signed. There is more on the sponsor page, and on the records rules in 21 CFR Part 11 for veterinary studies.

What it does not do yet: SAS and SEND exports. Guidance #197 says data sent to CVM typically arrive as SAS transport (XPT) or XML files and expects a conversion from CSV to change nothing, so that step, and the submission itself, stay with the sponsor.

Sources

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