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Responsibility by Clause (draft)

Goal: For each clause, see which of the four parties does what.

NOTE

Draft

Each "What the clause asks" cell is a short paraphrase, to be checked against eCFR (for Part 11) and the published Annex 11 before publishing. Read the rule itself, not this summary. Built means OpenX does this today. Coming means it is specified and not built yet. No row says a clause is met: that is for your QA and your auditor.

The four parties are OpenX, your app, your login system (the directory in App Identity) and your QA. See the Validation Pack for who each one is.

Every row has one more line for your QA: it validates the whole process, as you run it. Vendor data alone is not enough.

21 CFR Part 11 §11.10: controls for closed systems

ClauseWhat the clause asks (paraphrase)OpenXYour appYour login systemYour QA
§11.10(a)The system is validatedPublishes this pack, the trace, the IQ and OQ outline and a change notice per release (draft)Validates its own signing flowIs part of the validated set-upOwns the validation and its decision
§11.10(b)Accurate, complete copies in readable and electronic formFull signature records on read; CSV and JSON export (built); a printable certificate (coming)Shows signatures where people need themNoneChooses which copies inspectors get
§11.10(c)Records are protected for their retention periodStorage in your subscription; retention periods; Protected, then Locked when you press Lock permanently (built)NoneNoneSets retention and decides when to lock
§11.10(d)Access is limited to authorised peopleThe sign right Workspace.Provenance.Sign (built); API Manager rules on the sign route (built)Decides who may sign what, in its own screensHolds the accountsReviews who holds access
§11.10(e)Secure, time-stamped audit trailsThe Provenance hash chain, server time on every record (built); refused signings recorded (coming)NoneKeeps its own sign-in logReviews the trail; keeps the login system's log as long as needed
§11.10(f)Operational checks enforce the order of stepsSignature ceremonies; the optional two-person rule (built)Enforces its own order of steps (for example, review before approval)NoneDefines the order in procedures
§11.10(g)Authority checksThe sign right, and the meaning checked against the workspace's list (built)Decides which meaning a person may use; OpenX does not read that from its access rulesNoneDefines who may sign with which meaning
§11.10(h)Device checks, where neededNoneChecks its own input sourcesApplies its own device policyDecides where this applies
§11.10(i) and (j)Training, and written policies that hold people accountable for their signaturesDocuments the product (this site)NoneNoneOwns training and the policy
§11.10(k)Control of system documentationDated docs and a change notice per release (draft)Controls its own documentationControls its own documentationControls the copies it relies on

§11.50: what a signature shows

ClauseWhat the clause asks (paraphrase)OpenXYour appYour login systemYour QA
§11.50(a)(1)The signer's printed nameSignerPrintedName from the login's verified name, on every signature (coming); a login with no name is refused (coming)Never sends the name itself; a name in the request is ignoredGives the name claim in its ID tokenConfirms the name reads as a printed name
§11.50(a)(2)Date and time of signingSignedAt, from the server clock, in UTC (built)NoneNoneNone
§11.50(a)(3)The meaning of the signatureMeaning, checked against the workspace's list (built)Shows the meaning in the "you are signing this" momentNoneSets the workspace's list of meanings
§11.50(b)Those items are under the same controls as the record, and appear in readable formsThe whole signature is sealed and chained (built); the certificate shows each item, as text, never as an image (coming)Shows them where it shows the recordNoneConfirms the readable forms it relies on

§11.70: linking a signature to its record

ClauseWhat the clause asks (paraphrase)OpenXYour appYour login systemYour QA
§11.70A signature is linked to its record so it cannot be cut, copied or moved to another record by ordinary meansBindingDigest is the server's own digest of the record; a digest the signer did not see writes nothing; the link is re-checked on every read, verify and export; each signature is sealed by your workspace's own Key Vault key (built). The login itself is made for that record and meaning (coming)Sends the digest it showed; uses the published nonce function (coming)NoneDecides on the storage level; the link's strength rests on storage refusing changes, which is firmest once Locked

§11.100: general requirements

ClauseWhat the clause asks (paraphrase)OpenXYour appYour login systemYour QA
§11.100(a)Each signature belongs to one person and is never reused by or given to anyone elseRefuses jobs (built); refuses apps, AI calls and other non-persons by name (coming); one same-person rule across sign-ins (coming)Never signs on its own wordGives each person their own accountForbids shared accounts in procedure
§11.100(b)The organisation verifies a person's identity before giving them a signatureNone: OpenX does not check identity documentsNoneHolds the verified accountsOwns identity checks
§11.100(c)The organisation certifies to FDA that its electronic signatures are bindingNoneNoneNoneOwns the certification

§11.200: signature components and controls

ClauseWhat the clause asks (paraphrase)OpenXYour appYour login systemYour QA
§11.200(a)(1)At least two distinct components, such as an ID and a passwordChecks a fresh login from your login system, made for this record, used once; keeps the login time and methods on the signature (coming)Starts a forced login for each signingAsks for the components, and must really ask (see below)Sets the login policy and tests it
§11.200(a)(1)(i) and (ii)Within one continuous session, the first signing uses every component and later ones at least one; outside one session, every component each timeEach login signs once, so each signature rests on its own login (coming)Forces a login per signing, or per batchHonours the forced loginDecides how its sessions read against this clause
§11.200(a)(2)Used only by its genuine ownerThe login's person must be the caller (coming); a different person's login is refused (built for today's sign-in again)Keeps tokens on its serverAuthenticates the personOwns account hygiene
§11.200(a)(3)Misuse needs two or more people to collaborateAn app-made token is never the proof (coming), so holding an app's key is not enough to sign; the optional two-person rule (built)Never makes tokens that stand for a personIssues the only accepted proofDecides where two people are required
§11.200(b)Biometric signaturesNot applicable: OpenX has no biometric signatureNoneAny biometric factor is its ownDecides if it applies

The limit no design removes. OpenX sees that a login happened, not that a password was typed again. A single sign-on bounce can look like a fresh login. So your login system or your app must force the login, and your validation must test it.

§11.300: identification codes and passwords

ClauseWhat the clause asks (paraphrase)OpenXYour appYour login systemYour QA
§11.300(a)No two people share the same ID and password pairNone: OpenX keeps no passwordsNoneKeeps accounts uniqueChecks it
§11.300(b)Codes and passwords are checked or renewed from time to timeNoneNoneIts password and account policySets the period
§11.300(c)Lost or compromised credentials are withdrawn and replaced under controlNoneNoneDisables and reissuesOwns the procedure
§11.300(d)Safeguards stop unauthorised use and report attemptsRecords refused signings (coming); signature events for refusals (coming)Reports what it refusesLocks out and logs failed loginsReviews and acts on the reports
§11.300(e)Devices that carry codes, such as tokens or cards, are testedNoneNoneIts own devicesOwns the tests

EU Annex 11 §14: electronic signature

ClauseWhat the clause asks (paraphrase)OpenXYour appYour login systemYour QA
§14 (a)The same effect as a handwritten signature within the companyNone: this is the company's ruleNoneNoneOwns the policy
§14 (b)Permanently linked to the recordAs §11.70 above (built, and the login tie is coming)As §11.70NoneAs §11.70
§14 (c)Includes the date and time it was appliedSignedAt, server clock, UTC (built)NoneNoneNone

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