Author: Bob Matje

Robert “Bob” Matje, PE, CPIP, has held increasing levels of responsibility in several branded and generic pharmaceutical companies including general management. He has also lead reliability and maintenance, environmental, health and safety, automation, capital and qualification teams and served as the Serialization Project Management Office (PMO) Lead for Endo and for Pfizer, which included responsibility for establishing the serialization governance, scope development, schedule and cost. Bob is a member of the International Society of Pharmaceutical Engineering (ISPE) and was recently elected to his second term on ISPE’s International Board of Directors. Bob earned a BS in Engineering at Lafayette College and an MS in Engineering at Villanova University. He is a Registered Professional Engineer in Pennsylvania and was awarded his Certified Pharmaceutical Industry Professional certification in 2012.

Upgrading Windows Operating System

Upgrading Windows Operating System

Ensuring Data Integrity through Optimal Security and Performance 

Executive Summary

As Microsoft releases new updates and editions of Windows Operating System (Windows OS), it is harder to verify a device or network is running the right software for its job. This guide explains which editions of Windows OS are appropriate for the pharmaceutical industry to use, in compliance with FDA regulations and guidelines. Ultimately, upgrading to the latest edition of Windows OS will provide users the greatest functionality, especially in areas like serialization where large amounts of data is stored. However, an OS still in its lifecycle, with the most recent updates installed, can provide necessary data security and protection. This technology is the foundation of good data integrity, from record creation to destruction. Following this guide will ensure a device has the proper Windows OS for required functionality, and that it is maintained throughout the future.

 

Introduction

Windows Operating System (Windows OS) is software that controls the basic functions of a computer. With several Windows OS editions and updates, it can be complicated to know if a device has the proper OS for optimal security and performance. This guide provides an explanation of the differences in Windows OS, as well as guidelines for the use and importance of the appropriate one. This approach follows existing regulations and good manufacturing practices and applies to the most recent changes in pharmaceutical data, including serialization. It will explain the process of upgrading a device to a new edition of Windows OS, or updating a device’s current edition of Windows OS, and how to stay informed when to do so.

 

Supported Windows OS

With several different Windows OS editions, and versions of each one, monitoring the proper OS for a device can be confusing. To demystify this complexity, it is best to have a clear understanding of the important distinction between supported Windows OS and unsupported Windows OS. Supported Windows OS is a product Microsoft actively sells and maintains. This maintenance mostly consists of releasing updates that fix bugs and offer performance improvements that were initially overlooked, but also includes customer support services. Each edition of Windows OS continues to be supported until the end of its lifecycle. Currently supported Windows OS include Windows 8.1 and several editions of Windows 10.

 

When an edition of Windows OS concludes its lifecycle, Microsoft classifies it as unsupported. Unsupported Windows OS places the security and performance of systems at risk as Microsoft no longer releases updates that patch vulnerabilities nor provides customer support for it. Though there are exceptions where Microsoft updates unsupported Windows OS, as was done recently for Windows 7, this is volitional and rare (Warren, 2020). Because the use of unsupported Windows OS has inherent risks, Microsoft notifies their customers of important information regarding where a product lies in its lifecycle. To best determine if a particular device’s OS is supported, as well as key dates in its lifecycle, view the Windows Lifecycle Factsheet.

 

The Microsoft Product Lifecycle

The Microsoft Lifecycle Policy outlines the phases of Windows OS as it matures until being replaced with a newer edition and becoming obsolete. Microsoft states: 

“Every Windows product has a lifecycle. The lifecycle begins when a product is released and ends when it’s no longer supported. Knowing key dates in this lifecycle helps you make informed decisions about when to update, upgrade, or make other changes to your software.” (Windows Lifecycle Fact Sheet, 2020)

 

While distinguishing these key dates is important, it is also necessary to understand what they signify. Microsoft has different lifecycle policies for Windows OS, and with them different phases.

 

Fixed Lifecycle Policy

The Fixed Lifecycle Policy applies to editions of Windows OS like Windows 7, Windows 8, and some versions of Windows 10. This policy ensures at least 10 years of Microsoft Support for its respective product. Over this period, Microsoft maintains editions of Windows OS through two phases: Mainstream Support and Extended Support. Mainstream Support has a duration of at least 5 years, during which Microsoft provides security updates and incident assistance. Following Mainstream Support, Extended Support has a duration of at least 5 years and provides customers with security updates and additional paid assistance. Key dates for these phases can be found in Table 1, below, or the Windows Lifecycle Factsheet. For more information, view Microsoft’s Fixed Lifecycle Policy.

 

Edition of Windows Operating SystemsMainstream Support End DateExtended Support End Date
Windows 10 Enterprise LTSCJanuary 9, 2024January 9, 2029
Windows 10 Enterprise 2016 LTSBOctober 12, 2021October 13, 2026
Windows 10 Enterprise 2015 LTSBOctober 13, 2020October 14, 2025
Windows 8.1January 9, 2018January 10, 2023
Windows 7, service pack 1January 13, 2015January 14, 2020

Table 1: Key Fixed Lifecycle Dates for Windows OS

Modern Lifecycle Policy

More recently, Microsoft introduced the Modern Lifecycle Policy to incorporate newer products and services. Under this policy, Windows OS is supported if the conditions below are satisfied: 

  • Customers are current, as per the servicing and system requirements of the OS
  • Customers are licensed to use the OS
  • Microsoft currently offers support for the OS

Should a Windows OS require customer action to maintain its current status, this policy ensures a minimum of 30 days’ notice prior to its degradation. Additionally, should a Windows OS become obsolete without a successor, this policy ensures a minimum of 12 months’ notice prior to being classified as unsupported. Key dates of the Modern Lifecycle Policy can be found in Table 2, below, or the Windows Lifecycle Factsheet. For more information, view Microsoft’s Modern Lifecycle Policy.

 

Edition of Windows Operating SystemsEnd of Service for Home, Pro, Pro Education, and Pro for Workstations EditionsEnd of Service for Enterprise and Education Editions
Windows 10, version 2004May 27, 2020December 14, 2021
Windows 10, version 1909 November 12, 2019May 11, 2021 
Windows 10, version 1903May 21, 2019December 8, 2020
Windows 10, version 1809November 13, 2018November 10, 2020
Windows 10, version 1803April 30, 2018November 12, 2019

Table 2: Key Modern Lifecycle Dates for Windows OS

Security

Though it may seem trivial, upgrading to a Windows OS that is routinely updated via Microsoft Support is essential to data security. Updates are periodically released and are only available to supported Windows OS. They provide performance improvements for greater functionality, but more importantly patch vulnerabilities in the OS software. Though infrequent, these vulnerabilities are inherent within Windows OS and can be exploited by malware to access a device or network. Microsoft continually monitors for these weaknesses and newly discovered flaws to protect against them. This is why using a supported and updated OS is essential for data protection.

 

A recent case that best illustrates the risk to organizations without a fully updated, supported edition of Windows OS is the May 2017 WannaCry ransomware attack. WannaCry exploited a vulnerability in several editions of Windows OS to block access to, if not delete, stored files, before spreading throughout networks. It reached 150 countries and infected 230,000 computers, promising to restore access to data in exchange for bitcoin. One affected system, that of the UK’s National Health Services (NHS), interrupted appointments, surgeries, and ambulance transport, inducing costs totaling over $100 million as a result (What is WannaCry Ransomware?, 2020). While the computers impacted were running Windows OS with Microsoft Support, only those that had not installed the latest updates – patches that were released two months prior to the attack – were infected. This malware is one of many that demonstrate the importance of ensuring devices run on fully updated and supported editions of Windows OS in order to protect sensitive data.

Figure 1: WannaCry Ransomware Window (Whittaker, Z., 2019)

Performance

A device running a fully updated, supported Windows OS allows users to receive features that maximize use. Routine updates provide performance improvements, and upgrades to newer editions of Windows OS allow for even greater functionality. In Windows 10, this functionality includes security features like Windows Defender Antivirus, a program that gives added protection from third-party software, and automatic updates, an element which eliminates manual steps required to keep a system secure. Additional performance benefits included in the latest Windows OS incorporate greater cross-platform support, better cloud integration tools, and advances in user interface. All of these allow users to interact with data safely and efficiently.

 

Regulations and Guidelines

Within pharmaceutics, requirements and guidelines for specific data protections require the security and performance an updated edition of Windows OS provides. The FDA states:

“CGMP regulations and guidance allow for flexible and risk-based strategies to prevent and detect data integrity issues. Firms should implement meaningful and effective strategies to manage their data integrity risks based upon their process understanding and knowledge management of technologies and business models.” (Clark et al., 2019, p. 17)

The security and performance offered by this technology serves as a basis for this, as the proper version of Windows OS minimizes data integrity risks. The FDA further stipulates systems “that create, modify, maintain, or transmit electronic records shall employ procedures and controls designed to ensure the authenticity, integrity, and, when appropriate, the confidentiality of electronic records.” (Title 21: Food and Drugs, 2020) This requisite too can only be ensured with a trusted OS.

 

Likewise, the MHRA states:

“Data integrity is fundamental in a pharmaceutical quality system which ensures that medicines are or the required quality” (Clark et al., 2019, p. 47)

“The effort and resource applied to assure the validity and integrity of the data should be commensurate with the risk and impact of a data integrity failure to the patient and environment” (Clark et al., 2019, p. 48)

Thus, devices running updated and supported Windows OS are fundamental to not only drug quality but ultimately public safety. These standards ensure stored data is protected from modification or loss, and, when used in conjunction with proper practices, creates the trust and validation required between government, industry, and patients.

 

Good Manufacturing Practice

Good Automated Manufacturing Practice (GAMP) is one of the many FDA guidelines Windows OS supports. While multifaceted, one aspect of GAMP is the integrity of records and data through data governance. Data governance is defined by the MHRA as: 

“The sum total of arrangements to ensure that data, irrespective of the format in which it is generated, is recorded, processed, retained, and used to ensure complete, consistent, and accurate record throughout the data life cycle.” (Clark et al., 2017, p. 21)

It is composed of three main areas: technology, process, and people. Seen in Figure 2, each area is organized under its own controls that guide decisions for data integrity and security. 

 

Technical Controls

Technical controls prevent the unauthorized deletion or modification of regulated data and records via user access arrangements. Additionally, they preserve copies of data through a combination of backup and recovery processes and validated security controls (Clark et al., 2017, p. 19). Using a supported Windows OS sets the foundation for strong technical controls. It ensures the most secure access to and modification of data records, and that integrated controls cannot be evaded due to flaws in the software system. The installation of released updates to supported Windows OS is a key part of maintaining this security. In addition, upgrading to the newest editions of Windows OS provides access to the latest backup and recovery technologies, such as cross-platform connected devices and tools for the cloud.

Figure 2: Controls for Data Governance (Clark et al., 2017, p. 21)

Procedural Controls

Procedural controls minimize the risk to data integrity, identify the residual risk of following the principles of ICH Q9, and assess risk associated with third-party software (Clark et al., 2017, p. 19). While they relate to the processes that utilize technology rather than the technology itself, using a supported Windows OS is still important in maintaining these controls. Windows OS aids in the process of ensuring data integrity by inherently minimizing risk to it. Features like Windows Defender Antivirus help evaluate the safety and risk associated with third party software, in addition to the use of similar programs available.

 

Behavioral Controls

Behavioral controls relate to the maintenance and training for data integrity, the preservation of a work environment that promotes data transparency, and the ownership of data over its lifecycle. The maintenance of data integrity and preservation of data transparency are upkept through the protections and channels that are included in supported Windows OS functionality. While the ultimate ownership of data relates to the actions of the users that behavioral controls govern, Windows OS plays a key role in its protection through the data lifecycle.

 

The Data Lifecycle

The data lifecycle represents all phases of data from its initial creation to final destruction. Depicted in Figure 3, it contains five phases. A supported Windows OS ensures data integrity throughout each phase.

 

Data Creation

Data can be created manually through user input or via the use of an instrument or measuring device. Its integrity can be compromised at the point of creation by lacking appropriate accuracy, completeness, content, and meaning. Windows OS limits these risks by safely storing created data through properly authorized channels.

 

Processing

Data processing is the phase in which the required information is formatted and derived from created data. Though it varies by product and business process, data processing has a direct impact on product quality and patient safety (Clark et al., 2017, p. 35). Windows OS supports programs necessary for secure processing.

 

Review, Reporting, and Use

During review, reporting, and use, data is used for informed decision making, through defined and verified processes most typically related to record documentation. Windows OS serves as the foundation for appropriate data access during documentation activities.

 

Retention and Retrieval

Throughout retention and retrieval, data is readily available for any entity or regulator approved to review it. Windows OS protects stored data for the length of its retention period, as in accordance with defined and verified processes and approved procedures. 

 

Destruction

Data destruction occurs at the conclusion of the retention period, when all regulations for destruction are met and the data is completely cleared to be disposed. Given appropriate controls, Windows OS will not destroy data until properly authorized and protect against data destroying malware.

 

In this way, a device with Windows OS ensures only those with proper access can create, process, review, and destroy data. Working with the newest editions of Windows OS bolsters these functions through data management via cloud tools and other performance capabilities. 

Figure 3: The Data Lifecycle (Clark et al., 2017, p. 33)

 

Serialization

The Drug Supply Chain Security Act (DSCSA) provides regulations to help the industry identify suspect and illegitimate products in the prescription drug distribution system in the United States. A core practice that supports this legislation is serialization, a process to track and trace pharmaceutical drug products through the complete supply chain. This process identifies legitimate products at the unit, inner-pack, case, and pallet level of production and relies heavily on the security and integrity of data. From data protection to cross-platform access and storage via the cloud, Windows OS acts as a pharmaceutical company’s foundation for security and integrity throughout this process.

 

Upgrade Considerations

As in upgrading any system, there are important factors to be considered. Though it depends on age and configuration, most devices operating on Windows 7 or newer can be fully upgraded within an hour (Upgrade to Windows 10: FAQ, 2020). Pending on the age of a computer, in some instances, a new device will be required to upgrade to the newest versions of Windows OS. Additionally, some devices may require freeing up or acquiring additional storage space. Large-scale deployment of the latest editions of Windows 10 can be arranged through the use of the Microsoft Development Tool kit. For more information, view Microsoft’s Windows Update: FAQ.

 

Windows OS Maintenance 

Fortunately, once a device’s OS is upgraded to Windows 10, maintaining the software takes less effort than before. Without any work from the user, automated updates on the latest editions of Windows OS will install routine fixes and improvements as they are released by Microsoft. These updates can be scheduled within the Update and Security tab of the Settings menu. Details regarding updates available, and the most recent updates installed, can be viewed on this tab as well. While Microsoft sends notifications related to the end of a product’s lifecycle, the best resource to find information related to a specific Windows OS and the timeframe to upgrade to a newer edition is the Windows Lifecycle Factsheet

 

Conclusion

This guide explains the importance of a fully updated and supported Windows Operating System in the pharmaceutical industry, and the processes Microsoft follows to release improvements and phase out old software. Through these processes, devices running Windows OS receive the latest security features and performance improvements that protect the access, storage, and transfer of data. In compliance with Good Manufacturing Practices, Windows OS provides the infrastructure to uphold the latest pharmaceutical standards as well as international regulations and guidelines. The latest editions of Windows OS automate updates and emphasize timeframes to upgrade to new OS software, making such standards and practices easier to follow. Running devices and networks on a fully updated Windows OS with Microsoft Support will ensure the highest degree of software security and data integrity for a pharmaceutical company. 

 

References

Clark, C., Jones, C., Margetts, T., Newton, M., Perez, A., Reid, C., . . . Wingate, G. (2017). ISPE GAMP Records and Data Integrity Guide. Tampa, FL: ISPE.

Fixed Lifecycle Policy – Microsoft Lifecycle. (2019, September 19). Retrieved August 31, 2020, from https://docs.microsoft.com/en-us/lifecycle/policies/fixed

Grynoch, T. (2018). Data Lifecycle. Retrieved August 31, 2020, from https://nnlm.gov/data/thesaurus/data-lifecycle

Lindsay, G., Hall, J., Keller, L., Poggemeyer, L., Lich, B., Hernandez Avedon, M., . . . Mariano Gorzelany, A. (2020, August 13). Windows 10 deployment scenarios (Windows 10) – Windows Deployment. Retrieved August 31, 2020, from https://docs.microsoft.com/en-us/windows/deployment/windows-10-deployment-scenarios

Modern Lifecycle Policy – Microsoft Lifecycle. (2020, January 10). Retrieved August 31, 2020, from https://docs.microsoft.com/en-us/lifecycle/policies/modern

Title 21: Food and Drugs. (2020, August 28). Retrieved September 01, 2020, from https://www.ecfr.gov/cgi-bin/text-idx?SID=63804c565597c0de4c2f5628c5381d47

Upgrade to Windows 10: FAQ. (2019, July 29). Retrieved August 31, 2020, from https://support.microsoft.com/en-us/help/12435/windows-10-upgrade-faq

Warren, T. (2020, January 27). Microsoft Forced to Create a Free Windows 7 Update Just Days after Updates Ended. Retrieved September 01, 2020, from https://www.theverge.com/2020/1/27/21082228/microsoft-windows-7-black-wallpaper-fix-update-support-patch

What is WannaCry Ransomware? (2020, June 11). Retrieved August 31, 2020, from https://www.kaspersky.com/resource-center/threats/ransomware-wannacry

Whittaker, Z. (2019, May 12). Two years after WannaCry, a million computers remain at risk. Retrieved August 31, 2020, from https://techcrunch.com/2019/05/12/wannacry-two-years-on/

Windows Lifecycle Fact Sheet. (2020, August). Retrieved August 31, 2020, from https://support.microsoft.com/en-us/help/13853/windows-lifecycle-fact-sheet

Windows Update: FAQ. (2020, August 11). Retrieved August 31, 2020, from https://support.microsoft.com/en-us/help/12373/windows-update-faq

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Tim was an integral member of the Lafayette Motorsports Team, helping develop the school’s electric formula car for the 2020 FSAE competition. He acted as the lead mechanical engineer of the vehicle’s Tractive Voltage System, applying his knowledge of hardware and software to design the high voltage batteries that powered the motor. Other colligate projects include the exploration of semi-autonomous robots and their functionality with machine learning capabilities.

 

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Tim is also an Eagle Scout and actively supports his local community.

 

‘We are very excited about having Tim on board and look forward to continuing to grow RemTech to better serve our clients’ state John Hartwig and Bob Matje, principals of RemTech.  ‘Tim brings a wealth of knowledge in current computer science trends and will help enormously with supporting our client’s data management and efficiency through automation and knowledge sharing.’

 

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