BayesPeaQCSV / CSA
Bayes Pharma · Quality assurance programme

Making QMS validation evidence understandable.

Initial CSV / CSA technical audit of BayesPeaQ, beginning with Deviation from Open to Closed and extending to shared GxP platform controls.

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01 / Workflow scope

Deviation from Open to Closed

Six governed lifecycle states. QC acknowledgement is an Open-stage activity rather than a separate record status.

Lifecycle in scope
OpenReport & QC acknowledgement
TriageQC disposition & CFT
InvestigationScientific review
Impact assessmentProduct & patient impact
QA reviewReadiness & authority
ClosedElectronic signature & retention

Approved return-for-rework paths preserve historical records and require renewed review where material scientific content changes.

02 / What exists

Foundations observed in source code

Code mechanisms exist, but still require formally attributable validation execution.

01
Governed workflow rules

Defined stages, authorized transitions, accountable work assignments and controlled rework.

02
Revision and concurrency controls

Persisted revision checks and transactional record, audit and task writes.

03
Independent investigation review

Scientific conclusion context checks and separation between author and reviewer.

04
Electronic-signature foundation

Defined meaning, reauthentication, signed revision and governed transition persistence.

05
Tenant and role safeguards

Authenticated identity and tenant-scoped record access boundaries.

06
AWS resilience configuration

Encrypted Multi-AZ PostgreSQL with backups, deletion protection and non-public access.

03 / Findings register

11 prioritized assurance findings

A code-level concern is not automatically a reproduced runtime vulnerability. An evidence gap does not prove a control is absent.

No remediation claimed
Showing 11 findings
CSV-01P1 priority
Deviation workflow

Stage-specific editing authority

Some generic record-editing paths do not yet demonstrate a complete stage, field and role authorization matrix.

Next action: Enforce one server-side authorization matrix across every write path; qualify denied and permitted actions.

Negative OQ required
CSV-02P1 priority
Evidence integrity

Consistent evidence eligibility

Evidence safety and verification checks should share a single conservative policy across the workflow.

Next action: Require eligible security, integrity and source status consistently for reviews and stage handoffs.

Negative OQ required
CSV-03P1 priority
Validation evidence

Release-specific qualification dossier

The initial assessment did not establish a complete approved requirements-to-deployment validation package.

Next action: Build one version-locked dossier with URS, risk assessment, executed tests, deviations, release approval and evidence.

Documentation outstanding
CSV-04P1 priority
Change governance

Repository and release safeguards

Code-change authorization and deployment approval need independently demonstrable enforced controls.

Next action: Require controlled review, immutable release references and verified deployment evidence.

Control review needed
CSV-05P2 priority
Electronic signatures

Fresh review of signed revisions

A signature dialog should always present the current governed record revision when reopened.

Next action: Refresh review state on every signing session; verify stale-view recovery.

Browser OQ required
CSV-06P2 priority
Electronic signatures

Recovery after signing interruption

Reauthentication and failed-signature recovery need attributable evidence and consistent operator guidance.

Next action: Qualify interrupted signing and retries without allowing an unsigned transition.

Reliability OQ required
CSV-07P2 priority
Test assurance

Behavioral browser coverage

Selected code-pattern checks do not replace executed role-based system qualification.

Next action: Use authenticated browser/API OQ with persisted state and audit assertions.

Test upgrade needed
CSV-08P2 priority
Access control

Administrative versus Quality authority

Technical administration and GxP review rights need clear segregation and denial testing.

Next action: Approve a role matrix and qualify administrative negative cases.

Policy review needed
CSV-09P2 priority
Audit trails

Independent tamper evidence

Internal hash-chain checking should be complemented by independently protected retention and assurance evidence.

Next action: Qualify export, preservation, restoration and tamper detection.

Assurance evidence needed
CSV-10P2 priority
Disaster recovery

Application-level recovery qualification

Resilient database configuration is present; recovery of the complete QMS record/evidence chain still needs an executed drill.

Next action: Test application, database and evidence restoration against RPO/RTO and integrity criteria.

Restore OQ needed
CSV-11P2 priority
Controlled releases

Single-release evidence traceability

Every deployment, build and approval claim must refer to the same immutable execution and revision.

Next action: Reconcile source, pipeline, artifact, deployment and post-release evidence by execution ID.

Release review needed
04 / Operational qualification

24 proposed Deviation test cases

Intended as an OQ protocol starting point. Each case requires frozen source SHA, real execution evidence, test owner, reviewer and exception status.

0 executed in this assessment
Showing 24 proposed tests
TestStageQualification objectiveRiskExecution status
DEV-001OpenIncident record number, time, immutable original report and reporter attributionHighProposed · not executed
DEV-002OpenUnauthorized reporter, identity and tenant spoofing rejectionCriticalProposed · not executed
DEV-003OpenDuplicate submission protection and single audit lineageHighProposed · not executed
DEV-004OpenProduct, batch and site relationship validationHighProposed · not executed
DEV-005QC acknowledgementEvidence reviewer independence from original reporterCriticalProposed · not executed
DEV-006QC acknowledgementSource integrity and changing security-state negative casesCriticalProposed · not executed
DEV-007QC acknowledgementExactly one governed acknowledgement; remediation of duplicatesCriticalProposed · not executed
DEV-008Open → TriageOnly assigned QC Manager may advance; stale transitions deniedCriticalProposed · not executed
DEV-009TriageConsistent QC disposition and escalation decisionsHighProposed · not executed
DEV-010Triage → InvestigationNamed CFT notifications, responses and objectionsHighProposed · not executed
DEV-011InvestigationNotebook can be edited only in active stage and by the proper roleCriticalProposed · not executed
DEV-012InvestigationConclusion evidence and independent scientific reviewCriticalProposed · not executed
DEV-013InvestigationScientific rework invalidates stale accepted conclusionsCriticalProposed · not executed
DEV-014InvestigationGeneric editing cannot bypass later-stage authorityCriticalProposed · not executed
DEV-015Impact AssessmentNamed Department Head assignment and independent assessmentHighProposed · not executed
DEV-016Impact AssessmentReturn for rework preserves history and renewal requirementsCriticalProposed · not executed
DEV-017QA ReviewQA ownership, SOP, evidence and CFT closure prerequisitesCriticalProposed · not executed
DEV-018QA Review → ClosedFresh authentication, signer authority, decision and exact revisionCriticalProposed · not executed
DEV-019QA Review → ClosedTwo distinct signatures for applicable high-risk decisionsCriticalProposed · not executed
DEV-020QA Review → ClosedAtomic closure during concurrent writes and simulated failuresCriticalProposed · not executed
DEV-021ClosedRead-only controlled record and preserved historyCriticalProposed · not executed
DEV-022Shared controlsMulti-tenant record, evidence, task and export isolationCriticalProposed · not executed
DEV-023Shared controlsTimezone, due-date and daylight-saving behaviorHighProposed · not executed
DEV-024Shared controlsRefresh, logout, expiry, retry and interrupted-session handlingHighProposed · not executed
05 / Cross-cutting controls

Shared platform qualification

Controls that must support every Quality workflow and tenant.

AreaCurrent foundationQualification required
Identity & tenantServer-derived identity and tenant-scoped record accessRun full cross-role and cross-tenant denial tests
Electronic signaturesSigned decisions tied to controlled revisionsExecute signer, reauthentication and failure-rollback OQ
Audit historyAttributable records with hash-chain checksValidate independent retention, retrieval and tamper evidence
Evidence & data integritySource hashes and independent review existUnify positive eligibility checks and execute negative OQ
Change controlControlled workflow and release procedures existTrace approved requirements to executed release artifacts
Runtime & monitoringContainer image pinning and central logs observedVerify monitoring, immutable build identity and rollback
Database & recoveryEncrypted Multi-AZ RDS; backups and deletion protectionDemonstrate documented, whole-system restoration
Human use & trainingRole-specific workspaces and governed tasksExecute human-role scenarios and approve operating SOPs
06 / Readiness path

Recommended qualification sequence

Risk-based, budget-conscious and accountable to a human Quality approver.

01
Freeze the system baseline

Record the exact deployed frontend and backend revisions, immutable artifacts, tenant configuration and approved intended use.

02
Close high-priority gaps

Unify stage authorization and evidence security-state policy, then run targeted negative tests.

03
Execute Deviation OQ

Complete all 24 synthetic, isolated workflow tests; preserve every failure and retest under a new evidence ID.

04
Qualify platform controls

Demonstrate tenant isolation, signature rollback, audit preservation, timeout behavior, recovery and deployment provenance.

05
Assemble validation documentation

Link requirements to risk controls, test protocols, execution records, exceptions, deviations and immutable release artifacts.

06
Obtain human QA authorization

Use independent Quality review for release approval and customer-specific intended-use qualification.

07 / Assurance criteria

What would justify a controlled readiness claim?

Exit criteria for a specific release, not universal certification.

Zero unresolved critical integrity, tenant-isolation, authorization or signature failures.
Passing executed positive and negative tests mapped to high-risk requirements.
Consistent evidence eligibility decisions, including security-state changes.
Exact build, source, deployment and post-deployment evidence traceability.
Documented and verified application, database and evidence restoration.
Authorized independent human QA review and accountable release approval.

Assessment methods: read-only review of two repositories and selected AWS service configuration. No authenticated end-to-end qualification, full suite run, restore exercise, penetration test or customer acceptance was performed for this snapshot. Applicable GxP requirements vary by intended use and jurisdiction.