When a clinical study is completed, research materials including data and documentation need to be prepared for long-term storage. It is important to research documents are stored and archived in a structured way in order to enable scrutiny and verification of research findings, and to repeat analyses.
All types of documents produced as part of the research activities of HEIs and other public agencies constitute research material, and most of these are public documents that must be archived according to the Archives Act (SFS 1990:782 (in Swedish). Some documents shall be screened after a specified time period, and some documents shall be preserved “forever”.
When research is conducted at a Swedish state-operated HEI, the research material shall be archived there. Raw datafiles, ethical approval, research documentation and published results shall all be archived. Most HEIs have personnel who can provide both practical help and advice. There are several non-state operated research principals covered by the same archiving and screening requirements, such as Chalmers University of Technology and Jönköping University.
A strategy for screening and archiving should be included already in the planning of a clinical study; please contact your research principal to learn about the guidelines and procedures for archiving and screening that apply in your organisation.
For some research fields, there may be more specific regulations, such as for medicine studies, where the European Medicines Agency's regulations (pdf, 184 kB) shall be followed.
The website of the Swedish National Data Service has further information on archiving and the Archives Act (in Swedish).
Screening of personal data
Screening means that public documents are discarded and/or destroyed. Destruction of public documents is, in principle, prohibited, unless it is supported by a screening regulation; that is to say there is a screening right. When data that are not public documents are removed, this is known as purging.
There are rules that may require you to screen personal data already while your clinical study is in progress. For example, personal data may only be handled for as long as necessary to fulfil the purpose of the handling. Personal data that is no longer needed shall be removed, but regulations and archiving and screening requirements must be complied with and fulfilled.
Specific rules for medicines or medical devices
There are specific rules to attend to conducting clinical studies on medicines or clinical investigations of medical devices.
Specific rules for medicines
Archiving clinical trials with medicines
The research documents that clinical investigators and sponsors are obliged to draw up and store before and during a clinical medicine study shall be archived for ten years after the study has ended and the final report has been drawn up. If the clinical study is part of a marketing application, the documents shall be archived for longer than ten years. The sponsor and clinical investigator may also agree that the documents shall be archived for longer than ten years.
Specific rules for medical devices
New rules apply from 26 May 2021 - but some are delayed (preliminary) until 15 July 2021. Updates regarding the rules from 15 July will be published early autumn.
What shall be archived?
In general, the sponsor of clinical investigations of medical devices shall archive items such as application documents for the permit to conduct the study, information about the product characteristics and risk management documentation. The sponsor shall also archive data in the form of CRFs, summary raw data files, data analyses conducted and result reports. All principal investigators in the study shall archive trial files and source data generated at the own trial location. Unless otherwise has been specifically approved by the regulatory authorities, the investigator shall only provide pseudonymised information to the sponsor, and never information that discloses the study participants’ identity, such as signed consent forms or code keys. More information on the documents to be held by the investigator and sponsor respectively following conclusion of the study is available in ISO 14155:2020, Annex E.
How long should the study documentation be kept?
The investigator shall then archive their documentation in readable format. There is no statutory regulation of how long the investigator’s documentation in a medical device study shall be archived; instead, this follows from the rules applicable to the operation the investigator works in. However, the main rule is that the archiving period is never shorter than ten years. The sponsor and investigator may also agree on a longer archiving period if suitable.
The sponsor shall archive their documentation for no less than ten years after the clinical investigation of the medical device has been conducted. If the product is launched on the market, the documentation must be kept for at least ten years after the last product has been sold on the market. For implants, the documentation shall be archived for 15 years.