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.

Pharmacies that are “public bodies” are governed under B.C.’s Freedom of Information and Protection of Privacy Act (FIPPA).  Public bodies covered by FIPPA are, with some exceptions, required to ensure that personal information is stored and access only in Canada.  There is no exemption for cloud storage.  Hospital pharmacies and pharmacies run by a provincial health authority may fall under this category.  A private sector pharmacy that is under contract to a public body to provide pharmacy services for the public body may also fall under this category.

The PharmaNet database is subject to FIPPA.  Therefore, any information in PharmaNet or obtained from PharmaNet must be accessed, disclosed and stored in Canada.