9.2 Confidentiality Agreements

Pharmacies are required to comply with the policies and administrative requirements with regard to pharmacy confidentiality agreements established by the College of Pharmacists of British Columbia (CPBC), which include the following:

• Every person who has access to the dispensary must complete the appropriate confidentiality agreement (see table below)
• In the process of completing the confidentiality agreement, the pharmacy manager should explain to each person the reason for its completion and the confidential nature of dealings within the dispensary.

The confidentiality agreement appropriate for each person who has access to the dispensary is to be used:

Registrant confidentiality undertaking

Registrant Confidentiality Undertaking	This form is signed by each registrant registered with the College of Pharmacists of BC and is maintained on file by the College.
Designated Non-Pharmacist Owner, Non-Pharmacist Store Manager and/or Director Confidentiality Undertaking	This form is to be completed by a non-pharmacist storeowner, a non-pharmacist store manager or company director who has access to the dispensary.
Pharmacy Designated Support Person Confidentiality Undertaking	This form is used for a support person and any other store personnel who have access to the dispensary. This form should also be completed by anyone who accesses the dispensary after hours in the absence of the pharmacy manager, including janitors or overnight merchandising staff.
PharmaNet Third-Party Confidentiality Undertaking	This form is to be completed by the pharmacy software vendor, who may also have special authorized remote access capabilities.
Copies of pharmacy confidentiality agreements are available on the College of Pharmacists of BC PharmaNet web page, under Forms.

Completed forms should be retained by the pharmacy while the staff member is employed and for at least three years after their employment ceases for CPBC purposes. PharmaCare requires these documents to be retained for four years.

The signing of one agreement covers a pharmacist for all stores he/she may work in, as long as the undertaking is on file at the College. 

It is the pharmacy manager’s responsibility to ensure that everyone understands the forms being signed and that all staff comply with confidentiality procedures.

Each pharmacy must have a system in place to ensure that undertakings are signed on a regular basis, filed within the pharmacy, and made available to College representatives.

A copy should be given to the employee and the original filed in the pharmacy. 

Designated support persons who work at more than one pharmacy must sign a confidentiality undertaking at each pharmacy, even if all the pharmacies are part of the same chain.

>> For further information contact the College of Pharmacists of BC.

Community Health Practice Access to PharmaNet (ComPAP) allows authorized medical practitioners to receive up-to-date records of medications dispensed to a patient, in a timely and secure manner, at each registered practice site.

Physicians may register to access PharmaNet from one or more sites at which they practice. They may access PharmaNet only from within the sites for which they have registered.

Physicians who wish to access PharmaNet from health authority facilities must do so using Hospital Access to PharmaNet or Emergency Department Access to PharmaNet.

To be eligible to register for ComPAP access, physicians 

• Must deliver direct patient care at a medical practice site in British Columbia, and 
• Must be in good standing with their college

Each eligible physician must comply with the terms of the HLTH 4532 - Community Health Practitioner PharmaNet Access Agreement (PDF, 205KB). The Agreement and its companion documents are to be completed, signed and submitted in the manner established at the Community Health Practice Access to PharmaNet web page before access will be granted.

If a supervised person (or persons) will be accessing PharmaNet on behalf of the practitioner, the supervised person(s) must sign an Undertaking of Confidentiality and Security (PDF, 81KB). These documents must be retained on-site at the practice for auditing purposes.

Emergency Department Access to PharmaNet (EDAP) permits authorized individuals in hospital emergency departments, and diagnostic and treatment centres, to access patient medication profiles to help determine patient therapy in a timely and secure manner.

EDAP requires compliance with the confidentiality undertaking requirements established in the BC Professional and Software Conformance Standards Volume 3C: Business Rules - PharmaNet (PDF, 947KB), which include

• Confidentiality undertakings for physicians authorized to access PharmaNet information in the emergency department
• Confidentiality undertakings or pledges of confidentiality for nurses and clerical employees authorized to access PharmaNet information in the emergency department
• Confidentiality undertakings with technical support staff who may have access to PharmaNet through the course of their duties 
• An Emergency Department Access to PharmaNet Acknowledgement of Completion of Confidentiality Procedures

Hospital Access to PharmaNet (HAP) allows authorized physicians and pharmacists to request and receive up-to-date records of medications dispensed to a patient, in a timely and secure manner, at each registered hospital or designated mental health facility.

HAP requires compliance with the confidentiality undertaking requirements established in the BC Professional and Software Conformance Standards Volume 3C: Business Rules - PharmaNet (PDF, 947KB) and Hospital Access to PharmaNet, which include

• The hospital must complete and submit to the Ministry of Health an Undertaking to Complete Confidentiality Procedures for Hospital Access to PharmaNet
• Each physician accessing PharmaNet in the facility must be a member in good standing with the College of Physicians and Surgeons of British Columbia and sign an Undertaking of Confidentiality and Acknowledgment of Disclaimer by Physician for Hospital Access to PharmaNet. This document is retained by the facility
• Each supervised person acting on the physician's behalf in the facility must sign an Undertaking of Confidentiality and Acknowledgment of Disclaimer by Authorized Person for Hospital Access to PharmaNet.  This document is retained by the facility

No additional confidentiality undertaking is required for pharmacists since they have already signed a confidentiality undertaking which is retained by the College of Pharmacists of British Columbia. 

Further information see Hospital Access to PharmaNet.

Medical Device Distributor Claims Access to PharmaNet permits the submission of claims for eligible devices and supplies on PharmaNet.

Medical Device Distributor Claims Access requires compliance with the confidentiality undertaking requirements established in the Medical Device Distributor Claims Access to PharmaNet Policies and Procedures (PDF, 3.3MB), which include

• Completion and submission to the Ministry of Health of HLTH 4551 - Acknowledgement of Completion of Confidentiality Procedures for Medical Device Distributor Claims Access to PharmaNet (PDF, 134KB)
• The manager must complete a HLTH 4549 - Medical Device Distributor Claims Access to PharmaNet Undertaking of Confidentiality by Manager (PDF, 130KB)
• Before accessing PharmaNet, each authorized staff member must complete and sign a HLTH 4550 - Medical Device Distributor Claims Access to PharmaNet Undertaking of Confidentiality by Authorized Person (PDF, 130KB)
• Before the Medical Device Distributor manager allows any software vendor technician or staff to access PharmaNet, they must obtain a completed and signed HLTH 4552 - Medical Device Distributor - Software Vendor PharmaNet Third Party Confidentiality Undertaking (PDF, 125KB)

>> Copies of forms along with completion and submission instructions are available at Medical Device Distributors (MDD) Online Claims Access to PharmaNet.

A copy of all completed documents is to be maintained on file at the MDD web page.

All Ministry of Health and Health Insurance BC staff members or service providers who may handle or have access to confidential PharmaNet information or documents are subject to confidentiality provisions as a term of their employment or contract.