The quality lead is absent or the position remains vacant. Documents are waiting for review, deadlines continue and senior management becomes the destination for every question. A visible allocation of work and decisions now matters. Identify what is pending, who is authorised to act and where qualified cover is still missing.
By Daniel HerrmannUpdated 6 min read
The short answer
When quality leadership is vacant, first identify who is responsible for pending decisions and approvals. Record open work, deadlines and risks, check the deputy’s qualifications and authority, and document the handover. In the EU GMP context, duties may be delegated to designated deputies with appropriate qualifications. Qualified Person duties, however, may only be delegated to other Qualified Persons. Operational support does not replace these role arrangements.
Identify the decisions that cannot wait
Start with work that cannot wait until the vacancy is filled. This may include quality assessments, document approvals, open deviations or responses already promised. Separate preparing a document from assessing its content and formally approving it. These activities do not necessarily belong to the same person.
Create one list showing the item, deadline, possible consequence of delay and authorised decision-maker. Verify dates against the actual obligation: an internal preference and a binding deadline require different treatment. If the responsible approver is missing, show that explicitly as an unresolved issue.
Senior management should then decide which capacity will be provided and what takes priority. Do not conceal a vacancy by adding every responsibility to someone already at capacity. The first useful result is a workable allocation of responsibilities, not an artificially complete status report.
Distinguish quality leadership, quality control and QP duties
This article addresses EU GMP Part I for human medicinal products. In everyday language, “quality leadership” may refer to different functions. Establish which role is actually absent using the organisation chart, job description and applicable requirements. A title such as quality management representative does not by itself establish the required qualifications or authority.
EU GMP Chapter 2, sections 2.1–2.6, addresses adequate resources, clear responsibilities and corresponding authority. Duties of responsible personnel may be delegated to designated deputies with appropriate qualifications. The heads of Production and Quality Control must remain independent. Qualified Person duties have a specific boundary: they may be delegated only to other Qualified Persons.
Assess each decision being transferred individually. Project management experience does not automatically make someone an authorised approver. Site authorisations and national requirements also need consideration. The following working aids do not replace that assessment.
Record the assignment, boundaries and access
Document the cover arrangement in a way people can use during daily work. This table is a practical suggestion, not a prescribed regulatory form. Integrate it into your existing quality system.
A worksheet for a clear deputy arrangement
Field
Information to establish
Affected function
Which tasks and decisions belong to the vacant position?
Designated deputy
Who takes on each duty, from when and for what period?
Qualifications
Which relevant experience and task-specific training are documented?
Authority and limits
What may be prepared, assessed or approved, and what remains excluded?
Access
Which systems, documents and information are required?
Open work
Current status, next decision, deadline and location of evidence.
Escalation and return
Who decides when gaps arise, and how will duties be handed back?
Confirm acceptance of the responsibilities and communicate the arrangement to the affected departments. A document filed in a personnel folder does not, by itself, resolve questions in operations.
Prioritise the backlog by its consequences
Sort open work by the next necessary decision and its possible impact. An old formatting correction may be less urgent than a new issue affecting product quality. Ticket age is useful information, but it is not a sufficient prioritisation method.
A practical way to sort open items
Situation
Next step
A quality decision is waiting
Identify the decision-maker and the information they need.
A binding deadline is approaching
Verify the obligation, required response and responsible person.
Records are incomplete
Assign a bounded task to obtain the missing evidence.
An improvement has no immediate urgency
Set its priority deliberately and record the reason for deferral.
Record the rationale for significant priority decisions. Where quality impact is uncertain, the responsible function assesses it through the established procedure. Do not allow unresolved risks to disappear behind a green project status. A progress discussion should expose pending decisions, rather than merely count completed tasks.
Delegate operational work while preserving role boundaries
Support can often be defined as a concrete work package: collect records, reconcile a document inventory, structure evidence gaps or prepare a draft for technical review. Define inputs, the expected output, reviewer and completion criteria.
For example, existing requirements, test records and open points can be organised for selected validation activities. The output is a reviewable overview with explicitly identified gaps. The responsible function assesses the content, and formal approval comes from the authorised person. External preparation does not itself constitute approval.
Daniel Herrmann Consulting can support these bounded tasks and their coordination. This does not promise appointment as a QP, quality management representative or interim quality leader. We establish the appropriate service from the actual assignment. The compliance capacity gap page explains how work can be organised when internal resources are limited.
Make authority usable in daily work
After appointing the deputy, walk through a real item from receipt to decision. Can the person find the current document? Is the required information available? Does escalation reach the right contact? Can the person act in the relevant system within their authority?
Provide access for the assigned duties and record its allocation through the established procedure. Use personal permissions rather than the absent employee’s account. Conversely, system access does not establish professional approval authority. Check these two dimensions separately.
Inform affected interfaces, including Production, Quality Control, IT, project teams and external partners where relevant. Name the contact and the route for unresolved decisions. Under EU GMP Chapter 1, senior management retains responsibility for an effective and adequately resourced pharmaceutical quality system. Operational cover should make that responsibility actionable.
Plan the handback from the beginning
A temporary arrangement needs an ending that does not depend on individual memory again. Maintain a short decision record during the cover period: what was decided, on what basis and where is the evidence? Include unresolved matters, changed priorities and promised follow-up activities.
On return or recruitment, assign open tasks explicitly. Review responsibilities, deputy arrangements and access again. Also record the structural capacity gaps exposed by the vacancy. If resources remain insufficient, changing a name on the organisation chart will not resolve the issue.
Senior management benefits from a simple overview: decisions still pending, their owners and the capacity needed. That turns an individual’s overload into an organisational assignment that can be managed. Agree who keeps this overview current after the temporary arrangement ends.
Can senior management temporarily take over every approval?
A management position alone does not provide technical or regulatory approval authority. Check the required qualifications, responsibility and effective appointment for each decision. Senior management remains responsible for resources and a functioning organisation.
Can an external consultant cover the quality leadership role?
Engagement alone does not establish this. The function, qualifications, authority, authorisations and applicable requirements need assessment. A contract to prepare documents is not an automatic appointment as quality lead.
Can a QP delegate duties to an experienced project manager?
EU GMP Chapter 2.6 allows QP duties to be delegated only to other Qualified Persons. General project experience or advisory work does not replace that qualification.
What can be prepared before formal approval?
Existing records can be collected, status documented, gaps described and draft documents prepared. The assignment must identify who subsequently reviews the content and who has authority to approve it.
What belongs in the handover?
Open items, deadlines, decisions, responsibilities and evidence locations. Add the agreed authority, required access and escalation route. Adapt the specific format to your quality system and the duties being transferred.
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5b. Retention overview & justifications
A consolidated view of all retention periods with the rationale behind each one — the principle: minimal storage, clear purpose, documented basis.
Data categoryRetentionJustification
Server logs7 daysSufficient for technical fault analysis & security forensics — Art. 6 (1) (f) GDPR. IP anonymisation kicks in immediately on log close.
Contact enquiries12 monthsB2B sales cycle in pharma typically runs 6–9 months. 12 months covers follow-ups without unnecessary stockpiling. Statutory retention (e.g. § 257 HGB) only applies once a contract is concluded.
Lead magnetsup to 24 monthsUntil withdrawal of consent; 24-month cap covers documentation of consent (Art. 7 GDPR) and re-engagement cycle. Withdrawal at any time, deletion within 7 days of request.
Newsletter subscriptionactive subscription + 3 yrs consent logEmail + name only as long as the subscription is active. Consent log (timestamp + IP) retained 3 years to cover statutory limitation period (§ 195 BGB) for complaints under § 7 UWG.
Cookies (incl. analytics)30 min – 14 monthsPer-tool detailed in 6.9. GA4 capped at 14 months (the GA4 minimum, shorter possible only via property reset); all other tools below or equal to industry standard.
Cookiebot consent12 monthsMaximum window the EDPB considers reasonable for repeat-consent requests. After 12 months a fresh banner appears.
6. Cookies, analytics & tracking
This website uses analytics and tracking tools that go beyond pure reach measurement and create usage profiles. Personal data may be processed (in particular IP address, device and browser information, behaviour data) and transferred to third countries (including the USA). Legal basis is your consent pursuant to § 25 (1) TTDSG and Art. 6 (1) (a) GDPR. The consent is granted on first visit via our cookie banner and can be withdrawn at any time with effect for the future — see section 6.10 below. Withdrawal is as simple as granting consent (Art. 7 (3) GDPR); the lawfulness of processing carried out on the basis of consent prior to withdrawal remains unaffected.
6.0 Consent management (Cookiebot)
Provider: Cybot A/S, Havnegade 39, 1058 Copenhagen, Denmark (a Usercentrics company) — EU-based. Purpose: Cookiebot is the consent management platform (CMP) we use to document your consent in line with § 25 TTDSG and Art. 7 GDPR and to block analytics / tracking tools until you opt in. Data: Cookiebot stores a ‘CookieConsent’ cookie containing your consent state (categories, timestamp, anonymous identifier) and a server-side consent log. Retention: up to 12 months from the moment consent is given; renewed on each new visit after expiry. Legal basis: the processing of consent itself rests on Art. 6 (1) (c) GDPR (legal obligation to document consent). Third-country transfer: primary processing in the EU; sub-processors may include service providers outside the EEA under EU Standard Contractual Clauses. Data processing agreement: concluded with Cybot A/S. More info:Cookiebot Privacy Policy.
6.1 Google Analytics 4
Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (parent company: Google LLC, USA). Purpose: Tracking tool that goes beyond pure reach measurement. Google uses the collected data for the operation of GA4 and partly for its own purposes (no commissioned processing in the narrow sense for these purposes). Data: pseudonymous identifiers (client ID), IP address (shortened on EU server, see below), page views, dwell time, scroll depth, click events, device and browser information, approximate location (country / region from IP). Retention: up to 14 months for event-level data, then automatic deletion. IP shortening: The IP address is shortened on an EU server before being forwarded to the USA (‘_anonymizeIp’ equivalent in GA4 is active by default). Third-country transfer: data is processed on servers in the USA. Safeguards: EU Standard Contractual Clauses and the EU-US Data Privacy Framework (Adequacy Decision of 10 July 2023). Note that the supervisory authorities point out that the legal certainty gained may only be temporary; previous adequacy regimes (Safe Harbor, Privacy Shield) were invalidated by the CJEU. Data processing agreement: concluded with Google Ireland Ltd. More info:Google Privacy Policy, Browser opt-out.
6.2 Microsoft Clarity
Provider: Microsoft Ireland Operations Ltd., One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland (parent: Microsoft Corporation, USA). Purpose: Session recordings and heatmaps to improve usability. Note: session recordings are a particularly intensive form of processing — they can capture sensitive content even though input fields are masked by default. We have configured the strictest masking level (‘Strict’) for all form fields. Data: mouse movements, clicks, scroll behaviour, page views, device and browser information, shortened IP address, country. Retention: up to 12 months from the last recorded session. Third-country transfer: Microsoft is a US group; data may be processed on servers in the USA. Safeguards: EU Standard Contractual Clauses and the EU-US Data Privacy Framework. The reservations noted above for GA4 apply analogously. Data processing agreement: Microsoft Online Services DPA concluded. More info:Microsoft Privacy Statement.
6.3 Leadfeeder (Dealfront)
Provider: Dealfront Germany GmbH (Leadfeeder), Markgrafenstraße 36, 10117 Berlin, Germany — EU-based provider. Purpose: B2B identification of visiting companies based on commercially licensed IP-address databases (e.g. RIPE, ARIN, public corporate IP ranges). We use this to inform our sales outreach. The aim is identification of the company, not of an individual user. Important note from a data protection perspective: IP addresses can constitute personal data, particularly when combined with other data. We therefore treat Leadfeeder processing as relevant under GDPR. Data: IP address, page views, timestamp, dwell time, referrer. Data sources: Dealfront enriches IP data with publicly available company information and licensed B2B databases. Retention: up to 12 months on visit level; aggregated reports may be retained longer. Third-country transfer: Dealfront operates primarily on EU infrastructure; sub-processors may include US service providers under EU Standard Contractual Clauses. Data processing agreement: concluded with Dealfront Germany GmbH. More info:Dealfront Privacy Policy.
6.4 Google Ads
Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (parent: Google LLC, USA). Purpose: We use Google Ads conversion tracking and (where activated) remarketing to measure the success of advertising campaigns and to address visitors with relevant ads. Data: pseudonymous click ID (gclid), conversion event, conversion timestamp, device and browser information. Cookies used include `_gcl_au` (conversion linker) and `test_cookie` (doubleclick.net technical test cookie). Retention: `_gcl_au` up to 90 days, conversion logs in the Google Ads account according to Google retention settings. Third-country transfer: data is processed on Google servers including the USA. Safeguards: EU Standard Contractual Clauses and the EU-US Data Privacy Framework. Data processing agreement: concluded with Google Ireland Ltd. More info:Google Privacy Policy, Ad personalisation settings.
6.5 LinkedIn Insight Tag
Provider: LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland (parent: LinkedIn Corporation, USA). Purpose: The LinkedIn Insight Tag enables campaign measurement, audience analytics and (where activated) retargeting for LinkedIn ad campaigns. Data: IP address (truncated), timestamp, page URL, device characteristics, LinkedIn member ID where the visitor has been logged in to LinkedIn. Cookies used include `bcookie`, `lidc`, `bscookie`. Retention: up to 6 months for direct identifiers; aggregated campaign reports may be retained longer. Third-country transfer: data is processed on LinkedIn servers including the USA. Safeguards: EU Standard Contractual Clauses and the EU-US Data Privacy Framework. Data processing agreement: concluded with LinkedIn Ireland Unlimited Company. More info:LinkedIn Privacy Policy, LinkedIn opt-out.
6.5a Meta Pixel (Facebook Pixel)
Provider: Meta Platforms Ireland Ltd., Merrion Road, Dublin 4, D04 X2K5, Ireland (parent: Meta Platforms, Inc., 1601 Willow Road, Menlo Park, CA 94025, USA). Purpose: The Meta Pixel (also ‘Facebook Pixel’) enables reach measurement, conversion tracking and (where activated) retargeting for advertising campaigns on Facebook and Instagram. It lets us measure the effectiveness of our ads and show relevant advertising to visitors. Data: pseudonymous identifiers, IP address, device and browser information, referrer URL, triggered events (e.g. page view). Cookies used include `_fbp` (first-party cookie used to recognise the browser) and `_fbc` (click identifier derived from the `fbclid` URL parameter). If the visitor was logged in to Facebook / Instagram at the time of the visit, Meta can attribute the visit to the respective account. Joint controllership: for the collection and transmission of the data to Meta there is joint controllership within the meaning of Art. 26 GDPR between us and Meta; we have concluded Meta’s controller addendum for this. Meta is solely responsible for any subsequent processing of the data for its own purposes. Retention: `_fbp` up to 90 days; on the event level according to the retention settings in the Meta Events Manager. Third-country transfer: data is processed on Meta servers including the USA. Safeguards: EU Standard Contractual Clauses and the EU-US Data Privacy Framework (Adequacy Decision of 10 July 2023). The reservations noted above for GA4 apply analogously. Legal basis: your consent pursuant to § 25 (1) TTDSG and Art. 6 (1) (a) GDPR. The pixel is only loaded after you have given consent via our Cookiebot banner. More info:Meta Privacy Policy, Meta ad settings.
6.6 Google Tag Manager
Provider: Google Ireland Limited (see 6.1). Purpose: Google Tag Manager (GTM) is a tag-management system that loads other tracking tags (e.g. Google Analytics, Google Ads, LinkedIn Insight Tag) on this website. GTM itself does not set any cookies and does not collect personal data per se; it only orchestrates the tags loaded after consent. Data: technical request data (IP address, timestamp, user agent) is briefly seen by Google’s GTM-loader server. No persistent identifier is set by GTM itself. Third-country transfer: the GTM loader is hosted on Google infrastructure including the USA. Safeguards as in 6.1. Note: we have configured GTM so that no measurement tag fires before you have given consent via our Cookiebot banner. More info:Google Privacy Policy.
6.7 Cloudflare (CDN & bot management)
Provider: Cloudflare, Inc., 101 Townsend Street, San Francisco, CA 94107, USA, with EU representative Cloudflare Germany GmbH, Rosental 7, c/o Mindspace, 80331 Munich. Purpose: Cloudflare is used by our hosting provider as a Content Delivery Network (CDN) and security layer. The ‘__cf_bm’ cookie is set by Cloudflare’s bot-management to distinguish humans from automated traffic and to mitigate DDoS attacks and content scraping in real time. Why we consider this technically necessary: Without bot-mitigation our website would be vulnerable to credential-stuffing, scraping and DDoS attacks that compromise availability, integrity and the security of the personal data we process (e.g. lead-magnet form submissions, newsletter signups). Bot-mitigation is therefore a technical security measure within the meaning of Art. 32 GDPR (security of processing). Cloudflare itself classifies ‘__cf_bm’ as ‘strictly necessary’ (Cloudflare cookie documentation). Replacing Cloudflare bot-management would weaken the security of personal data on this site. Data: IP address, request headers, technical fingerprint of the request. No persistent identifier across sites. Retention: ‘__cf_bm’ cookie expires after at most 30 minutes of inactivity. Aggregated security logs at Cloudflare are retained briefly under Cloudflare’s standard retention. Legal basis: § 25 (2) Nr. 2 TTDSG (technically required to operate the requested service) and Art. 6 (1) (f) GDPR (overriding legitimate interest in a secure, available website). Third-country transfer: Cloudflare is a US group; data may be processed on servers in the USA. Safeguards: EU Standard Contractual Clauses and the EU-US Data Privacy Framework (Adequacy Decision of 10 July 2023). Please note that the legal certainty of the framework may be limited; the General Court of the EU has annulment proceedings pending (case T-553/23). Data processing agreement: concluded as part of the hosting contract. More info:Cloudflare Privacy Policy.
6.8 Google Search Console
Provider: Google Ireland Limited (see 6.1). Purpose: Google Search Console (GSC) lets us monitor how the site performs in Google’s search results — indexing status, search queries that lead to the site, click-through rates, technical crawl errors. Cookies / tracking on visitors: GSC itself sets no cookies on visitors of this website and runs no client-side script. The site ownership is verified by a static HTML meta tag and / or a DNS TXT record. Data: aggregated search analytics from Google’s side (search queries, impressions, clicks); these are not directly linked to individual visitors. The data is made available to us only in aggregated form. Legal basis: Art. 6 (1) (f) GDPR — legitimate interest in monitoring the site’s search visibility. Third-country transfer: the aggregated reporting is generated on Google infrastructure including the USA. Safeguards as in 6.1. More info:Google Privacy Policy.
6.9 Cookie storage durations
Session cookies are deleted when the browser is closed. Permanent cookies have the following maximum lifetimes: Google Analytics 4 — up to 14 months (data retention shortened to 14 months in GA4 settings); Microsoft Clarity — up to 12 months; Google Ads (`_gcl_au`) — up to 90 days; Meta Pixel (`_fbp`) — up to 90 days; LinkedIn (`bcookie`) — up to 6 months; Cloudflare (`__cf_bm`) — at most 30 minutes of inactivity; Leadfeeder — typically session-based, not stored on the device; CookieConsent (Cookiebot) — up to 12 months from the moment consent is given.
6.10 Withdrawal of consent
You can withdraw your consent at any time with effect for the future — withdrawal is as easy as granting consent:
1. Open cookie settings: click the ‘Cookie settings’ link in the footer to re-open the banner and adjust your choice (this controls all of GA4, Clarity, Google Ads, LinkedIn, Meta Pixel and Leadfeeder). 2. By email: send a short message to info@daniel-herrmann.io — we will block the relevant tools for you. 3. Per tool: for Google Analytics the official browser opt-out is available; for Google Ads under Ad personalisation settings; for LinkedIn under LinkedIn opt-out; for the Meta Pixel under Meta ad settings. Microsoft Clarity and Leadfeeder are controlled exclusively via our cookie banner.
The lawfulness of processing carried out on the basis of consent prior to withdrawal remains unaffected (Art. 7 (3) GDPR).
7. Web fonts
This website loads Google Fonts. Connection data (in particular the IP address) is transmitted to Google. Provider: Google Ireland Limited (see section 6.1). Legal basis: Art. 6 (1) (f) GDPR — legitimate interest in a consistent typographic presentation. As an alternative, fonts are also held in a local fallback so that font loading can fail safely without breaking the layout.
8. Technical and organisational measures (TOM)
To protect your data we implement appropriate technical and organisational measures pursuant to Art. 32 GDPR — among them: TLS encryption (HTTPS) for the entire site, encrypted database connections, server hosting in the EU (Kinsta / GCP Frankfurt), restricted admin access via individual accounts with strong passwords and 2FA, regular automatic backups, role-based access controls, a documented record of processing activities pursuant to Art. 30 GDPR, and data minimisation at the application level. We continuously review and update these measures.
9. Your rights
Under the GDPR you have the following rights:
Right of access (Art. 15 GDPR) — information about which of your personal data we process.
Right to rectification (Art. 16 GDPR) — correction of inaccurate data.
Right to erasure (Art. 17 GDPR) — deletion of your data where the legal conditions are met.
Right to restriction of processing (Art. 18 GDPR).
Right to data portability (Art. 20 GDPR) — receipt of your data in a structured, common, machine-readable format.
Right to object (Art. 21 GDPR) — to processing based on legitimate interest, including for direct marketing. See highlighted box below.
Right to withdraw consent (Art. 7 (3) GDPR) — at any time with effect for the future, see section 6.10.
Right to lodge a complaint (Art. 77 GDPR) — with a supervisory authority, in particular in the EU member state of your residence, your workplace or the location of the alleged infringement. Competent supervisory authority for our office location: Independent Data Protection Centre Saarland (Unabhängiges Datenschutzzentrum Saarland), Fritz-Dobisch-Straße 12, 66111 Saarbrücken.
Requests regarding these rights are to be directed to: info@daniel-herrmann.io. We will respond within the statutory period (usually one month).
10. Currency of this Privacy Policy
Last updated: 29 June 2026. We reserve the right to adapt this policy so that it always meets current legal requirements. The current version is always retrievable from this website.
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