Record Keeping

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.

What is an acceptable form of electronic signature?

Bylaw References: 

PODSA Bylaws - Definition of Electronic Signature

“electronic signature” means

(a) information in electronic form that a person has created or adopted in order to sign a record, other than with respect to a prescription signed by a full pharmacist for the purpose of prescribing, that is in, attached to or associated with a record, is secure and is only reproducible and used by that person; and,

What should be included in the pharmacy’s written record keeping policy?

Bylaw reference: PODSA Bylaws, s. 23.2

23.2. (1) A pharmacy manager must ensure that a policy is in place that:

(a) describes the pharmacy’s records filing system, the records format and the method and system for storing records,

(b) is compliant with the sections 23.1, 23.2 and 23.3 requirements; and

(c) is readily accessible to and understood by pharmacy staff.

Can prescriptions be destroyed after scanning and storing electronically?

Yes, most prescriptions can, but are not required to be, destroyed after scanning and storing, as long as all notes made on the prescription are captured in the scan. As per Pharmacy Operations and Drug Scheduling Act Bylaws s23.3(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 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.

What is required by the general record keeping requirements in s. 23.1(1) of the PODSA Bylaws?

Bylaw Reference: PODSA Bylaws s. 23.1(1):

23.1. (1) All records required to be kept under bylaws of the college or other legislation that regulates the practice of pharmacy shall be readable, complete, filed systematically and maintained in a manner that is secure, auditable and allows for easy retrieval.

This general record keeping requirement applies to all pharmacies, regardless of the type of records they keep.  The following provides more information on the terms used in s. 23.1(1) of the PODSA Bylaws.

“Readable”