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  • Specific Documents

    Please note that the abovementioned clauses are covered by the following:

    • clause 4.1 - Understanding the organization and its context can be evidenced by means of documents “List of Legal, Regulatory and Contractual Requirements”, generated by the 'Register of legal, contractual and other requirements' module, and "Risk Assessment and Risk Treatment Report", generated by the 'Risk register' module.
    • clause 5.1 Leadership and commitment can be evidenced by means of documents “Information Security Policy”, “List of Security Objectives”, “Risk Assessment and Risk Treatment Report”, “Risk Treatment Plan”, and “Management review report”.
    • clause 6.1.1 General, which refers to risks related to the Information Security Management System itself, can be evidenced by means of the “Risk Treatment Plan”.
    • clause6.1.2 Information security risk assessment can be evidenced by means of the “Risk Assessment and Risk Treatment Methodology”.
    • clause 9.1 Monitoring, measurement, analysis, and evaluation can be evidenced by means of the records defined on each policy and procedure you have implemented.
  • A.8.2.2 Labeling of Information

    Since you stated in the SoA that control A.8.2.2 Labelling of information is not applicable, then it is sufficient for you to include only N/A in the Labeling column (there is no need to exclude the column).

    Regarding controls A.8.2.1 Classification of information and A.8.2.2, you can implement only A.8.2.1 without implementing A.8.2.2 (i.e., you can define classification levels without the need to label media that contains it, although this is not common).

    For further information, see:

  • Adverse Event Reporting

    Yes, you can follow the same procedure. According to Article 16 from the MDR, if the CE mark of the manufacturer stays on the medical device, you do not consider a manufacturer, but rather the distributor.

    1 a) makes available on the market a device under its name, registered trade name, or registered trademark, except in cases where a distributor or importer enters into an agreement with a manufacturer whereby the manufacturer is identified as such on the label and is responsible for meeting the requirements placed on manufacturers in this Regulation.

    For more information, see:

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