1st requirement of Part 11 compliance is "Validation" = fit for the intended use. So same logic will apply for Migration if that database is to be Part 11 compliant
Another way to think about it is, don't you think you would have at least some URS around migrating data? That it successfully did happen ? The input data matched the output? Now think how will you test that requirement. Once you define a test case and do it. That's what Validation would be in this specific case
But the argument here I have is, both the current and new database is managed by the Vendor. The risk of Data integrity is less, hence a simple row count comparison with before and after should be enough and no need of writing a formal protocol and a report.
So I wanted to see how others are addressing this instance.
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