Record Keeping

A family member of a deceased patient is asking for records related to prescriptions. Are pharmacy professionals allowed to release this information?

Pharmacy professionals must release personal health information if requested to do so by a person who is legally authorized, in writing, such as an executor of the estate. 

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What should the pharmacy do if they receive a request for information from law enforcement? (e.g. video surveillance footage)

Information can be disclosed when complying with a court-ordered subpoena, warrant or order, or otherwise compelled by a person or body with appropriate jurisdiction. Also, you may disclose the information if you believe doing so will reduce a risk of significant harm to the health and safety of any person. This does not constitute legal advice, and we recommend you seek your own legal counsel. Please refer to the Health Professions Act Bylaws, section 72, for more information.  

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Can electronic records be stored on a cloud? If yes, does the cloud need to be located in Canada?

The College does not have restrictions on cloud storage.  However, as with all records, pharmacies must ensure that data is stored and accessed in accordance with applicable privacy law.

Pharmacies that are private-sector organizations are governed by B.C.’s Personal Information Protection Act (PIPA).  PIPA does not contain restrictions on the storage of, or access to, personal information from outside Canada.  Organizations subject to PIPA may therefore use cloud-based storage services outside Canada. Many community pharmacies will fall under this category.

Are all electronic records required to be maintained in a system that complies with the new technology requirements?

Bylaw reference: PODSA Bylaws, s.23.3(1):

23.3. (1) A pharmacy may maintain electronic records containing personal health information if the pharmacy has the equipment, software and systems necessary for the input, storage, use, protection and retrieval of records that are required to be kept under bylaws of the college or other legislation that regulates the practice of pharmacy.

Are electronic equivalents acceptable for all College-required documentation, including invoices and documentation in respect of the purchase, receipt or transfer of drugs, confidentiality forms, narcotic reconciliation records etc.?

Yes, pharmacies may keep all records required by the College in electronic format. Only records containing personal health information are required to be maintained in a system that complies with s. 23.3 of the PODSA Bylaws.  

Are all pharmacies required to comply with the new technology requirements?

Bylaw Reference: PODSA Bylaws s. 23.3(1):

23.3(1) A pharmacy may maintain electronic records containing personal health information if the pharmacy has the equipment, software and systems necessary for the input, storage, use, protection and retrieval of records that are required to be kept under bylaws of the college or other legislation that regulates the practice of pharmacy.

In addition, the detailed technology requirements are set out in s. 23.3 of the PODSA Bylaws.