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Services Providers. Ivan Soto

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Learning Objectives

Learning Objectives

ƒ

At the end of this session we will have covered:

ƒ

Types of Managed Services

ƒ

Outsourcing processOutsourcing process

ƒ

Quality expectations for Managed Service providers

ƒ

Roles and Responsibilities

G it i d i ht

ƒ

Governance, monitoring and oversight

ƒ

Service Level considerations

ƒ

Inspection Readiness

ƒ

Case Study: Promotional Materials System Implementation

(3)

Types of Managed Services

Types of Managed Services

Our Way Is the Way”

Keep process ownership, execute with supplier’s people

May be onsite or supplier’s site (InSourcing, Offshoring)

“Go Away”

Hand everything to supplier to manage on your behalf

Supplier owns processes over time (Outsourcing)

“Do It Their Way”

Move to supplier’s standard processes and environment

(4)

Outsourcing Process

Outsourcing Process

Change Management Exit Management Phase 5: Change

Service Level and Contract Management Phase 4: Monitor Planning Implementation Phase 3: Implementation Baseline Specification Phase 2: Specification and Selection

(5)

Business Case

Business Case

Benefits Analysis

Benefits Analysis

• Focus should be on core, value adding business activities

• Cost optimizationCost optimization

• Improved service portfolio and performance management

• Simplified organization

(6)

Business Case

Business Case

Risk Analysis

Risk Analysis

• Misalignment of business objectives – quality vs cost vs volume

• Cost optimizationCost optimization

• Loss of control and visibility of regulated services

• Loss of intellectual property control

• Improved quality standards

(7)

Specification and Selection

Specification and Selection

Baseline Assessment

Baseline Assessment

• Regulatory impact of application and assets and services to be outsourced

• Current quality status

• Current documentation and records management practices

• Process map for outsourced activities with associated roles and responsibilities

• Can be used for SLACan be used for SLA

• Identify support gaps

(8)

Specification and Selection

Specification and Selection

Supplier Selection Considerations

Supplier Selection Considerations

• Cost, technical response, responsiveness, quality approach

• Experiences of other organizations with the supplierExperiences of other organizations with the supplier

• Supplier audit

(9)

Implementation

Implementation

Transition to outsource company

Transition to outsource company

• When services, assets and applications will be migrated

• When resources will transition to the outsource organization

• When processes and procedures will transition

• Service disruption management

(10)

Governance

Governance

Business management

Business management

Contract management

Service and Quality management

Customer and supplier relationship management

(11)

Monitor

Monitor

Audits

Audits

• Compliance with processed and standards

P f

R

ti

Performance Reporting

(12)

Contract Change & Exit Management

Contract Change & Exit Management

Evaluating needs for additional or reduction of

Evaluating needs for additional or reduction of

services

Service Level Agreements

(13)

Quality Expectations for Service

Quality Expectations for Service

Providers

Providers

Providers

Providers

Documented processes and controls in place

Training of the processes and controls to those that are

Training of the processes and controls to those that are

expected to implement them

Qualification of the individuals that are implementing the

Qualification of the individuals that are implementing the

processes and controls

D

t d

id

f

f l

ti

f th

Documented evidence of successful execution of the

processes and controls

M t i

it i

d

l

ti

f th

ti

f

(14)

Quality Expectations for Service

Quality Expectations for Service

Providers (cont.)

Providers (cont.)

Providers (cont.)

Providers (cont.)

• Quality Management Systems

(15)

Quality Expectations for Service

Quality Expectations for Service

Providers (cont.)

Providers (cont.)

Providers (cont.)

Providers (cont.)

• Quality Management Systems

• Service Management

• Help Desk

• Demand Management

• Service Specification

(16)

SOP’s for Service Providers

SOP’s for Service Providers

• SOP’s will vary depending on the type of managed servicesSOP s will vary depending on the type of managed services

• SOP’s should address the following:

• System impact assessments on patient safety, product quality, and data integrityy p p y, p q y, g y

• Roles and Responsibilities

• Life cycle approach

• Risk management

• Risk management

• System Specifications

• Validation and Qualification

• System Operation and Maintenance

• Record and Data Management

• Security Managementy g

(17)

SOP’s for Service Providers

SOP’s for Service Providers

• SOP’s will vary depending on the type of managed servicesSOP s will vary depending on the type of managed services

• SOP’s should address the following:

• System impact assessments on patient safety, product quality, and data integrityy p p y, p q y, g y

• Roles and Responsibilities

• Life cycle approach

• Risk management

• Risk management

• System Specifications

• Validation and Qualification

• System Operation and Maintenance

• Record and Data Management

• Security Managementy g

(18)

SOP’s for Service Providers

SOP’s for Service Providers

(19)

Roles and Responsibilities

Roles and Responsibilities

The responsibility for data integrity ultimately remains with

The responsibility for data integrity ultimately remains with

the regulated company

Roles and responsibilities must be defined and clear to both

Roles and responsibilities must be defined and clear to both

parties

The regulated company may leverage supplier knowledge

The regulated company may leverage supplier knowledge,

services and artifacts

The supplier is accountable for the quality delivery of its

The supplier is accountable for the quality delivery of its

services

(20)

Governance, Monitoring, and

Governance, Monitoring, and

Oversight

Oversight

Oversight

Oversight

Identification of sensitive or critical business data

A dit (f

f

)

Audits (frequency, focus)

Access provisioning and roster reviews

Privileged Access

Audit trails

Audit trails

Business Continuity / Disaster Recovery

Service Level measurements

(21)

Service Level Considerations

Availability and performance

Availability and performance

Change management

g

g

Quality of service

Security

B

i

ti

it / B

k

d R

Business continuity / Backup and Recovery

(22)

Inspection Readiness

Document Management

Document Management

Record Retention

Record Retrieval

Clear response time expectations

(23)
(24)

Background

H

t d

li

ti

i

l

t d

d

d b

Hosted application implemented and managed by

the vendor

Application allows users to plan, discuss, agree

concepts and track promotional materials

Vendor works with more than 100 companies and

over 25,000 users across the life sciences industry

(25)

Implementation Approach

F ll

i

i t

l

d

f

d

Following our internal procedures we performed

the following activities:

Initial Regulatory Assessment

Initial Regulatory Assessment

Part 11 Assessment

Risk Assessment

Risk Assessment

(26)

Implementation Approach (cont.)

I iti l R

l t

A

t

Initial Regulatory Assessment:

Based on GxP requirements

Identifies GxP applicability

Identifies GxP applicability

Identifies applicable regulatory requirements

Identifies systems that require validation

Identifies systems that require validation

Identifies the need to implement procedure controls

(SOP’)

(27)

Implementation Approach (cont.)

P t 11 A

t

Part 11 Assessment:

Identifies applicable Part 11 requirements

• Close or Open System

• Close or Open System

• E-signatures requirements

• Electronic records requirements

(28)

Implementation Approach (cont.)

Ri k A

t

Risk Assessment:

Identifies whether the application is High, Medium or

low risk

low risk

Validation effort is based on the risk level

Procedure controls are based on risk level

(29)

Implementation Approach (cont.)

S

li

A

t

Supplier Assessment:

Suppliers QMS

System Development Life Cycle

System Development Life Cycle

Design Controls

(30)

Implementation Approach

A

t R

lt

Assessment Results:

GxP impact

Low risk

Low risk

Vendor met supplier assessment criteria

(31)

Implementation Approach

L

d

t d

lid ti

d

t

Leverage vendor created validation documents

Perform User Acceptance Testing

No on-site vendor audit

Leverage vendor SOP’s

Create SOP’s for user access, software

(32)

Implementation Approach

Vendors SOP’s: • Vendors SOP s: • Business Continuity • Client charter • Code of Conduct • Complaints Procedure C t t S ft Li i A t

• Contract - Software Licensing Agreement

• Employee Confidentiality Agreement

• Employee Training Records

• Risk Management

• SOP Approval Process

• Training SOPTraining SOP

• Network / Server access Procedure

• IT Security Policy

• Internal System Inventory

• Hardware asset records

• Security Incident Management

• Data Backup Plan

• Intrusion Detection Policy

• User Registration and Privilege Policy

• Development SDLC policy

• Development SDLC template documents D l t Ch C t l li

• Development Change Control policy

• Security / Vulnerability Identification Procedure

• CFR Part 11 Compliance

(33)

Summary

Cl

d T

h i

l O

i

Cloud Technical Overview

Security & Data Integrity

Change Management

Risk Based Validation Approach

(34)

Summary

D i

thi

i

d th f ll

i

During this session, we covered the following

concepts:

• Types of Managed Services

• Types of Managed Services

• Outsourcing process

• Quality expectations for Managed Service providers

• Roles and Responsibilities

• Governance, monitoring and oversight

• Service Level considerations

• Service Level considerations

• Inspection Readiness

• Case Study: Promotional Materials System Implementation

(35)

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