CAPA Plan - Response to ICON Audit
Document Information
| Field | Value |
|---|---|
| Document Title | Corrective and Preventive Action Plan - ICON Audit Response |
| Document Reference | CAPA-ICON-2026-001 |
| Audit ID | IA-10766 |
| Audit Date | 16-20 February 2026 |
| Audit Type | Routine/Surveillance |
| Auditor | Mori Miharu, Principal Auditor, Technology Quality Assurance, ICON |
| Auditee Organization | AI Labs Legit Health |
| Vendor Contact | Saray Ugidos, Quality and Regulatory Affairs Manager, AI Labs |
| Target Response Date | 10 April 2026 |
| Document Date | April 2026 |
| Status | Submitted for Client Review |
| Version | 1.0 |
Purpose and Scope
This Corrective and Preventive Action (CAPA) Plan has been prepared by AI Labs Legit Health in response to the audit conducted by ICON (Audit ID: IA-10766) on 16-20 February 2026. The purpose of this document is to:
- Acknowledge and address all findings identified during the audit
- Provide root cause analysis for each finding
- Detail corrective and preventive actions with clear ownership and timelines
- Demonstrate our commitment to continuous improvement
This CAPA Plan covers all findings from the ICON audit and applies to Quality Management, Product Development, Regulatory Affairs, and IT departments.
Finding Summary
| Rating | Count | Description |
|---|---|---|
| Critical | 0 | - |
| Major | 1 | SDLC and CSV deliverables for mobile/web application not available (AF-20551) |
| Minor | 1 | Technical documentation of the medical device not available at the time of audit (AF-20553) |
| Other | 1 | Document control process to be enhanced (AF-20554) |
| Total | 3 |
MAJOR FINDING
AF-20551 — SDLC and CSV deliverables for mobile/web application
| Field | Value |
|---|---|
| Global Category | System controls |
| Sub-Category | Development, Validation & Testing |
| Severity | Major |
References:
- EU MDR Annex I sections 17.3, 17.4, 23
- EU MDR Article 10(4), 10(11)
- EU MDR Annex II section 1.1(j)
- ISO 13485 clauses 7.3, 7.1, 4.2
- ICH GCP E6 R3 sections 3.16, 4
Finding Description:
SDLC and CSV deliverables for a system component (mobile application or web application) were not available at the time of the audit. Although the vendor demonstrated that their QMS is structured in alignment with ISO 13485, objective evidence demonstrating the data input and output processes at the end-user interface level was not available. The SDLC and CSV deliverables relevant to the end-user interface (mobile and/or web application) had not been established or made available.
Areas requiring follow-up:
- Clarification of the mobile device provisioning model (BYOD vs vendor-provided)
- Definition of the mobile application development lifecycle (core SDLC/CSV controls + study-specific configuration management)
- Updates to the QMS to formally incorporate mobile and web application development activities
- Documentation of end-to-end data flow (input at mobile/web level → AI processing → output presentation)
Investigation Summary (incl. Root Cause)
Root Cause: Legit Health's QMS and procedural framework were originally designed around the core AI medical device (backend API and AI models). The clinical trial web application (delivered as a Progressive Web App — PWA) was treated as a service delivery channel managed under GP-009 (Sales) rather than as a formal software component requiring dedicated SDLC/CSV documentation.
At the time of the audit, the following already existed but were not consolidated into a single, auditable framework:
- Data flow documentation existed in SP-009-005 (Implementation Plan Helpers for Clinical Trials) showing the end-to-end flow from participant login through CloudFront, S3, EBS, AI services, RDS, to data transfer endpoints.
- System architecture for the core medical device (API/AI backend) was documented in R-TF-012-029 (Software Architecture Description). However, R-TF-012-029 covers the medical device product, not the clinical trial WebApp — which is a separate service delivery platform. A dedicated architecture document for the clinical trial WebApp did not exist.
- Project-specific BYOD documentation existed in project records, describing the BYOD model, WebApp access via browser URL, image capture workflow, and anonymization — but this was project-specific rather than procedural.
- Integration workflows were documented in SP-009-006 covering Iframe and JSON-only integration patterns with detailed sequence diagrams.
The root cause is the absence of a general procedure that mandates, for every clinical trial project with a CRO, a standardized set of SDLC/CSV deliverables covering the frontend WebApp as a system component. The knowledge and capability existed within the engineering and quality teams; the procedural framework to enforce consistent documentation per project did not.
Clarification on the WebApp architecture: The Legit Health clinical trial WebApp is delivered as a Progressive Web App (PWA) — a web application accessed via a standard browser URL (e.g., studyname.clinicaltrials.legit.health). It is not a native mobile application and does not require installation from an app store. From a technical perspective, it constitutes a web application, as noted by the Lead Auditor. This architecture simplifies device provisioning and eliminates app distribution complexities, while still requiring proper documentation of the runtime environment (browser, OS, camera, screen) since these are implicit system dependencies.
Response to Regulatory References
The following table provides a point-by-point response to each regulatory reference cited in the finding:
EU MDR Annex I, Section 17.3 — Software used in combination with mobile computing platforms shall be designed taking into account the specific features of the mobile platform (e.g., screen size, contrast ratio) and the external factors related to their use (varying environment as regards level of light or noise).
| MDR 17.3 Requirement | Response |
|---|---|
| Screen size | Minimum screen size of ≥ 5.5 inches defined in SP-009-011 to ensure adequate lesion visualization and UI interaction. The PWA's responsive design adapts to the device screen dimensions. |
| Contrast ratio | Image capture environmental guidance in SP-009-011 requires screen brightness sufficient for image review in the capture environment. The WebApp uses high-contrast UI elements designed for clinical settings. |
| Varying light levels | SP-009-011 mandates image capture environmental guidance for each project: adequate, even lighting; avoidance of direct sunlight, shadows, or flash; diffuse natural or artificial light preferred. These instructions must be provided to users via the study protocol or user instructions. |
| Camera considerations | Minimum rear camera resolution of ≥ 12 MP defined. The built-in Dermatological Image Quality Assessment (DIQA) system automatically evaluates image quality at capture time and rejects images that do not meet quality thresholds (blur, exposure, framing), mitigating the risk of substandard images due to device or environmental conditions. |
EU MDR Annex I, Section 17.4 — Manufacturers shall set out minimum requirements concerning hardware, IT networks characteristics and IT security measures, including protection against unauthorised access, necessary to run the software as intended.
| MDR 17.4 Requirement | Response |
|---|---|
| Minimum hardware | SP-009-011 defines minimum handset specifications per project: rear camera ≥ 12 MP, screen ≥ 5.5 inches, iOS ≥ 16 or Android ≥ 12, Safari ≥ 16 or Chrome ≥ 110. These specifications are documented and communicated to the sponsor/CRO for inclusion in the study protocol. |
| IT network characteristics | Stable internet connection (Wi-Fi or mobile data) required for image upload. The WebApp communicates exclusively via HTTPS/TLS 1.2+ with the Legit Health cloud infrastructure (CloudFront CDN → backend → AI services). Network requirements are documented in the project-specific data flow diagram. |
| IT security measures | All data transmission is encrypted via HTTPS/TLS 1.2+. Session-based authentication with secure credentials. No clinical data is stored locally on the device (no local persistence). Access is role-based and provisioned per user. The WebApp operates within Legit Health's cloud infrastructure (hosted on AWS). Protection against unauthorised access is enforced via authentication, authorization, and audit logging. |
| OS version requirements | Minimum OS versions (iOS ≥ 16, Android ≥ 12) ensure that devices have current security patches and support modern browser security features (e.g., Content Security Policy, Secure Contexts). |
EU MDR Article 10(4) — Manufacturers shall draw up and keep up to date technical documentation to allow conformity assessment.
| Requirement | Response |
|---|---|
| Technical documentation for WebApp | SP-009-011 mandates a complete study documentation package for each clinical trial project, including: device provisioning model, end-to-end data flow diagram, system architecture diagram, study-specific configuration document, validation report, and user instructions. These documents are maintained in the QMS (Docusaurus-based, version-controlled in Git) and are available for conformity assessment. |
| Handset requirements documentation | Minimum handset specifications are documented in SP-009-011 and instantiated per project in the project record (R-009-001). |
| BYOD rationale | Each project record must include a formal justification for the chosen provisioning model (BYOD or vendor-provided), documenting the rationale and risk considerations. |
EU MDR Annex II, Section 1.1(j) — A general description of the key functional elements, including software if appropriate, its composition, its functionality, and where relevant, labelled pictorial representations (diagrams, drawings).
| Requirement | Response |
|---|---|
| Key functional elements | The clinical trial WebApp is now explicitly scoped as a functional component of the system in SP-009-011 and in the project-specific system architecture diagram. The WebApp's role (image capture, data input, result presentation) is documented alongside the backend API, AI processing services, and data storage components. |
| Diagrams | SP-009-011 mandates a project-specific end-to-end data flow diagram and system architecture diagram for each clinical trial. These diagrams illustrate all system components (WebApp, CloudFront, backend, AI, RDS, S3), their interfaces, and data flows. A general template diagram is provided in SP-009-011 and SP-009-005, and each project instantiates it with project-specific details. |
| Handset/app dependencies | The WebApp's dependency on the device browser, camera, OS, and network is documented in the minimum handset specifications table in SP-009-011 and in each project record. |
EU MDR Article 10(11) + Annex I, Section 23 — Information supplied with the device (instructions to users/patients).
| Requirement | Response |
|---|---|
| Handset requirements communicated to users | SP-009-011 requires that minimum handset specifications are incorporated into the study protocol or other appropriate study documentation and provided as instructions to site staff, clinicians, or trial subjects. |
| Image capture instructions | Image capture environmental guidance (lighting, distance, background, focus, orientation) must be provided to users. This guidance is defined in SP-009-011 and must be included in the study-specific user instructions. |
| User instructions | SP-009-011 mandates project-specific user instructions for each clinical trial, including device requirements, image capture guidance, and study-specific operational information. These are generated as part of the study documentation package (Phase 4). |
ISO 13485 Clause 7.3 (Design and Development) and Clause 7.1 (Planning of Product Realisation)
| Requirement | Response |
|---|---|
| WebApp SDLC | SP-009-011 Phase 3 defines the core WebApp development controls: version control (Git), code review (pull requests), automated testing (CI/CD), cross-browser and cross-device testing, controlled deployments with rollback, and change control (GP-023). These controls apply to the core WebApp platform. |
| Study-specific configuration management | SP-009-011 Phase 3.2 defines study-specific configuration management: study URL, access control, feature toggles, scoring system configuration, anonymization settings, data transfer configuration, and image requirements. Each study's configuration is documented and version-controlled. |
| User environment planning | The BYOD provisioning model, minimum handset specifications, and environmental guidance address ISO 13485 Clause 7.1's requirement to plan for the user environment in which the product will be used. |
ISO 13485 Clause 4.2 (Documentation Requirements)
| Requirement | Response |
|---|---|
| Documentation availability | SP-009-011 Phase 4 defines the complete study documentation package that must be produced before go-live. Phase 5 establishes a mandatory Technical Readiness Review where all documents are verified as complete and accessible. All documents are maintained in the QMS with version control and audit trail. |
ICH GCP E6 R3 Section 3.16 (Computerised Systems) and Section 4 (Data Governance)
| Requirement | Response |
|---|---|
| Fitness-for-purpose | The WebApp's purpose, scope, and capabilities are defined per project in the feature scope document (SP-009-011 Phase 1.2). Validation evidence (Phase 3.3) demonstrates fitness-for-purpose through functional testing, image capture testing, DIQA validation, and data transfer validation. |
| Risk-based validation | Validation activities are scoped based on the study's feature set and risk profile. Core WebApp controls are validated once; study-specific configurations are validated per project. |
| Data lifecycle | The end-to-end data flow diagram (SP-009-011 Phase 2) documents the complete data lifecycle: capture → upload → processing → storage → transfer → output. Data integrity is ensured through HTTPS encryption, database-level audit trails, and controlled data transfer protocols (sFTP, S3, REST API) as defined in the Data Transfer Agreement. |
| Sponsor oversight | Project-specific dashboards, data export capabilities (CSV with filters), and scheduled data transfers enable sponsor/CRO oversight of the clinical data. Access controls ensure appropriate visibility per user role. |
Corrective Action
A new specific procedure SP-009-011 "Clinical Trial Project Setup and Technical Deliverables for CRO Engagements" has been created under GP-009 to formalize the requirements for every clinical trial project. This procedure is organized in 5 phases and mandates that each project must produce the following deliverables before go-live:
Phase 1 — Project Scoping and Device Provisioning:
-
Device Provisioning Model Document — Formal documentation of whether a BYOD or vendor-provided model is adopted, with justification. For BYOD (the standard approach), minimum handset specifications are defined in compliance with EU MDR Annex I Sections 17.3 and 17.4:
Specification Minimum Requirement Regulatory Basis Rear camera resolution