Cybersecurity for GxP Systems

Aligned with Annex 11 Section 15 & Annex 22

As GxP systems move to cloud and SaaS models, cybersecurity risks are no longer limited to internal infrastructure. External exposure, third-party dependencies, and human factors now directly impact data integrity, product quality, and regulatory compliance. 

With the revised EU GMP Annex 11  particularly Section 15 (Security), and the introduction of Annex 22, organisations are expected to demonstrate ongoing cybersecurity governance and assurance across the full system lifecycle—not just point-in-time controls. 

Tech Qualitas supports this through a combined consulting and platform-enabled approach. 

Our Cybersecurity Model

We help organisations manage cybersecurity for GxP systems through two complementary layers: 

Cybersecurity Governance
& Compliance Support

We act as an extension of your quality, compliance, and security teams to support: 

Third-Party & Supplier Cyber Risk Management

Assessment of third-party tools, service providers, and suppliers supporting GxP activities

Alignment of vendor cybersecurity oversight with Annex 11 and Annex 22 responsibilities

Support for supplier qualification, ongoing monitoring, and audit readiness 

Cybersecurity Gap Analysis & Documentation


Review of existing cybersecurity policies, procedures, and controls against Annex 11 Section 15  and Annex 22 expectations

Identification of gaps affecting GxP systems, suppliers, and audit readiness

Support in developing or refining required documentation and governance artefacts 

Customers and Regulatory Security Questionnaires

 

Support in preparing consistent, technically accurate responses to customer and partner security questionnaires
 
Translation of cybersecurity controls into clear GxP-relevant justifications

Alignment of responses with validated state and quality oversight 

Process & Workflow Optimisation

Review of development, release, and security workflows

Identification of bottlenecks where cybersecurity or compliance slows delivery

Practical improvements so security strengthens compliance without disrupting engineering velocity 

Continuous Cyber Risk Monitoring (Platform-Enabled)

To support ongoing assurance under Annex 11 Section 15, we provide access to a cyber risk monitoring platform that enables continuous visibility of external exposure relevant to GxP systems. 

  • Monitoring for brand misuse, data exposure, and sensitive information leakage across open, deep, and dark web sources

  • Early detection of potential risks impacting reputation, confidentiality, and regulatory trust
  • Identification and monitoring of externally exposed digital assets, including domains, sub-domains, cloud services, and unmanaged or “shadow” assets

     

  • Continuous scanning for vulnerabilities affecting externally accessible systems

     

  • Ongoing visibility to support risk assessment and remediation tracking
  • Ongoing assessment and risk scoring of third-party vendors

  • Support for continuous supplier oversight rather than periodic, point-in-time reviews
  • Evaluation of human-centric risks such as phishing and social engineering


  • Support for targeted awareness and education initiatives


  • Reinforcement of secure behaviours aligned with quality and compliance expectations

Continuous Risk Management

Cybersecurity risks impacting GxP systems are continuously identified and monitored

Sustained Control Effectiveness

Controls are maintained and reviewed throughout the system lifecycle

Controlled Third Party Risk

Supplier and external risks are actively governed, not assumed

Audit-Ready Risk Decisions

Cybersecurity decisions are documented, owned, and defensible during audits and inspections

How This Supports Annex 11 and Annex 22

Why Trust Tech Qualitas

We work as an extension of your organisation, helping you remain secure, compliant, and inspection-ready as systems, suppliers, and threats evolve.

Expert quality and compliance solutions for organizations with efficiency as a priority.

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