Hidden Sensitive Data Liability: Why Legacy Web Forms Put Life Sciences Organizations At Critical Risk
By Frank Balonis
The pharmaceutical and life sciences sector faces a paradox: while investing billions in cutting-edge R&D and advanced manufacturing technologies, many organizations continue collecting sensitive data through outdated web forms built without modern security protocols. These legacy systems have become critical vulnerabilities, exposing companies to data breaches, regulatory penalties, and operational disruptions that ultimately compromise research integrity and intellectual property protection.
The numbers tell a stark story. An analysis of 172 recorded incidents between January and late September 2025 confirms that the pharmaceutical sector is dominated by data-centric cybercrime, with ransomware accounting for 29.1% of all attacks and data breaches representing 26.7%. According to 2025 reporting, pharmaceutical data breaches average ≈$5.1 million per incident — well above the $4.44 million global average reported by IBM. Meanwhile, regulatory fines have intensified, with one-third of organizations experiencing breaches facing penalties and the share paying fines exceeding $100,000 increasing by 19.5% year over year.
Compliance Gap
Legacy web forms used for clinical trial recruitment, adverse event reporting, laboratory data collection, and regulatory submissions frequently lack the security infrastructure required under 21 CFR Part 11, GDPR, and GxP regulations. These aren't suggestions — they're mandates with substantial penalties for noncompliance.
Consider 21 CFR Part 11, which establishes requirements for electronic records and signatures in life sciences. The regulation requires systems to generate accurate audit trails that independently record who created, modified, or deleted data, complete with timestamps and reasons for changes. Legacy forms typically cannot provide this functionality, forcing organizations to maintain inadequate paper-based logbooks as alternatives.
Without automated, tamperproof audit trails, pharmaceutical companies cannot demonstrate data integrity according to ALCOA+ principles (Attributable, Legible, Contemporaneous, Original, Accurate, Complete, Consistent, Enduring, Available). FDA warning letters have specifically cited firms where "there is no assurance that your systems have appropriate controls to record all modifications to data."
GDPR presents equally serious challenges for pharmaceutical companies conducting clinical trials internationally or operating across multiple jurisdictions. Personal data, genetic information, and health records collected through web forms must be encrypted during transmission and storage. Yet many legacy systems transmit data over unencrypted connections or use outdated encryption protocols.
The financial consequences are severe. GDPR fines can reach €20 million or 4% of global annual revenue. For organizations operating internationally, data sovereignty violations can result in operational bans in entire countries.
Attack Surface Reality
The pharmaceutical sector has become a prime target for cybercriminals, and legacy web forms represent particularly vulnerable entry points. These systems are susceptible to SQL injection and cross-site scripting attacks — two of the most prevalent web application vulnerabilities. Ransomware activity hit a record monthly high in December 2024, highlighting year-end risk concentration for enterprises.
SQL injection occurs when legacy forms use string concatenation in database queries rather than parameterized queries. An attacker can modify form parameters to access clinical trial data, proprietary drug formulations, or manufacturing processes. Cross-site scripting allows malicious scripts to be embedded in web forms, compromising user credentials and hijacking authenticated sessions.
Authentication weaknesses compound these vulnerabilities. Legacy systems frequently lack multifactor authentication, implement weak password policies, and use insecure session management. Recent incidents underscore the operational impact. Inotiv, a pharmaceutical R&D company, was hit in 2025 when attackers encrypted parts of its network, shut down systems, and forced operations offline while claiming to have stolen over 170 GB of sensitive data. In Germany, pharmaceutical wholesaler AEP faced similar disruption when IT systems were partially encrypted, putting medicine deliveries to more than 6,000 pharmacies at risk. The Cencora breach in early 2024 exposed data from at least 27 pharmaceutical and biotechnology companies, resulting in a $40 million settlement agreement finalized in 2025.
Third-Party Risk Multiplier
When pharmaceutical companies use third-party web form platforms or cloud services, they create vendor relationships that extend their attack surface. Legacy implementations often use consumer-grade tools never designed for life sciences compliance — tools that cannot provide proper security documentation, lack encryption, and store data in unsecured locations.
This creates cascading liability. According to recent data, 87% of pharmaceutical companies report being negatively affected by breaches in their third-party ecosystem. Verizon's 2025 Data Breach Investigations Report revealed that third-party responsibility for breaches doubled from 15% to 30% between 2024 and 2025. When breaches originate from third-party systems, the average remediation cost reaches $4.8 million.
Clinical trials present third-party challenges. CROs and technology platforms collect patient recruitment data, informed consent documentation, and clinical endpoints worth hundreds of millions. Legacy forms in these environments often cannot enforce data localization requirements or provide the transfer safeguards required under GDPR's Schrems II decision.
Maintenance Cost Trap
Beyond security and compliance risks, many organizations spend 60% to 80% of IT budgets just maintaining legacy systems — starving modernization and security uplift. Organizations hesitate to modernize due to concerns about data migration complexity, system downtime during clinical trials, validation requirements for GxP systems, and high up-front costs.
Yet the cost of inaction escalates. IBM research indicates 58% of breach costs in pharmaceutical companies continue accumulating after the first year. This extended financial impact distinguishes pharmaceutical breaches from those in other sectors. The extended exposure period amplifies damages, regulatory scrutiny, and reputational harm with research partners and investors.
What Organizations Need To Do Now
Organizations using legacy web forms need to act immediately. Start by inventorying every form that collects sensitive data — clinical trial information, adverse event reports, laboratory results, regulatory submissions — and evaluate whether it meets 21 CFR Part 11, GDPR, and GxP requirements. Implement TLS 1.2 or higher encryption for all data transmission and AES-256 encryption for data at rest. Add multifactor authentication to all systems handling proprietary research data or clinical information. Verify security agreements are in place for every third-party form platform and assess vendor compliance practices.
Long-term compliance requires replacing legacy forms with validated, GxP-compliant platforms that provide built-in encryption, comprehensive audit trails meeting 21 CFR Part 11 requirements, role-based access control, and complete validation documentation including IQ/OQ/PQ protocols. Modern solutions must also offer data residency controls for GDPR compliance and integration capabilities with CTMS, EDC, and LIMS systems.
In terms of regulatory guidance, European Compliance Academy (ECA)/GMP guidance is explicit: systems without audit trails/user logins should be replaced in the short to medium term. As one expert notes, "no audit trail function will NOT work in a digitalized laboratory."
The pharmaceutical and life sciences sector cannot afford to treat web forms as low-priority infrastructure. Every form represents both a potential entry point for proprietary research data and an attack surface for sophisticated threat actors targeting intellectual property. Organizations that continue relying on legacy systems without modern security controls face mounting financial and operational consequences that will only worsen as regulatory scrutiny intensifies and attackers refine their tactics against known vulnerabilities.
The question is no longer whether to modernize web form infrastructure, but how quickly organizations can implement secure alternatives before the next breach makes the decision for them.
About The Author:
Frank Balonis is chief information security officer and senior vice president of operations and support at Kiteworks, with more than 20 years of experience in IT support and services. Since joining Kiteworks in 2003, Balonis has overseen technical support, customer success, corporate IT, security, and compliance, collaborating closely with product and engineering teams. He holds a Certified Information Systems Security Professional (CISSP) certification and served in the U.S. Navy. He can be reached at fbalonis@kiteworks.com.