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GDPR Data processing modelComputerized pharmacy management and statistical analysis of its sales

Organisation: PrivateSector: Health
This processing model covers the dispensing and patient records of a community pharmacy: management of patient files and payments, preparation and submission of NHS prescription claims for reimbursement (in England, to the NHS Business Services Authority, including through the Electronic Prescription Service), letters to prescribers and other healthcare professionals, cash register summaries, and the keeping of the prescription-only medicines register and of the controlled drugs register.

Purposes (9)

A purpose is the objective pursued by the setting up of your file. It indicates what the processing of personal data will be used for, its purpose. This purpose must be clear and understandable

1
Participation in epidemiological studies
Legitimate interest
2
Statistical studies based on anonymized information
Legitimate interest
3
Payment management
Legitimate interest
4
Editions of a cash register summary slip
Legal obligation
Companies Act 2006, s.386 and s.388: companies must keep adequate accounting records and preserve them for 3 years (private company) or 6 years (public company). Sole traders and partnerships must keep business records for tax purposes (HMRC).
5
Letters to prescribers and other healthcare professionals (e.g. clinical interventions, prescription queries)
Contract
6
Preparation and electronic submission of NHS prescription claims for reimbursement
Legal obligation
Community pharmacy contractors claim payment for NHS prescriptions from the NHS Business Services Authority (England), through the Electronic Prescription Service and the monthly FP34C submission, under their NHS terms of service.
7
Management of the patient's pharmaco-therapeutic follow-up file
Legitimate interest
8
Keeping of the controlled drugs register
Legal obligation
Misuse of Drugs Regulations 2001: controlled drugs registers kept under regulation 19 must be preserved for 2 years from the date of the last entry (regulation 23).
9
Keeping of the prescription-only medicines register (private prescriptions and emergency supplies)
Legal obligation
Human Medicines Regulations 2012, regulation 253 (pharmacy records): records of sales or supplies of prescription-only medicines must be kept and preserved for 2 years.

Data categories (4)

Personal data is any information relating to an identified or identifiable natural person. A natural person can be identified either directly (eg surname and first name) or indirectly (eg phone number, social security number, email or postal address, but also voice or image)

Information about the patient's lifestyle habits

Data details


Coordinates of relatives mandated to withdraw delivered products may be collected with the patient's consentrequired

Data conservation rules

Active base:

3 years from the last dispensing or intervention on the patient's file. No statutory period; the controller should set the period based on continuity of care.

Misuse of Drugs Regulations 2001, reg. 23; Human Medicines Regulations 2012, reg. 253; Companies Act 2006, s.388; NHS Records Management Code of Practice; Limitation Act 1980

Intermediate archiving:

Archived on separate media for the periods required for the relevant registers and records: - Controlled drugs registers and related records: 2 years from the date of the last entry (Misuse of Drugs Regulations 2001, reg. 23). - Prescription-only medicines register (private prescriptions, emergency supplies): 2 years (Human Medicines Regulations 2012, reg. 253). - Other patient and dispensing records: no single statutory period for community pharmacies; the controller should set the period based on the NHS Records Management Code of Practice and the limitation periods for claims (Limitation Act 1980). - Accounting records: 3 years (private company) or 6 years (public company) (Companies Act 2006, s.388).

Destruction

Health data

Data details


Data directly related to optical defectsrequiredsensitive data
Medical devicesrequiredsensitive data
Products delivered

Definition

Products delivered by the optician

requiredsensitive data
Adaptation measuresrequiredsensitive data
Prescriptions (pharmacy)requiredsensitive data
Prescriptionsrequiredsensitive data

Data conservation rules

Active base:

5 years from the last dispensing or intervention. No statutory period; the controller should set the period based on continuity of care and the NHS Records Management Code of Practice.

Misuse of Drugs Regulations 2001, reg. 23; Human Medicines Regulations 2012, reg. 253; Companies Act 2006, s.388; NHS Records Management Code of Practice; Limitation Act 1980

Intermediate archiving:

Archived on separate media for the periods required for the relevant registers and records: - Controlled drugs registers and related records: 2 years from the date of the last entry (Misuse of Drugs Regulations 2001, reg. 23). - Prescription-only medicines register (private prescriptions, emergency supplies): 2 years (Human Medicines Regulations 2012, reg. 253). - Other patient and dispensing records: no single statutory period for community pharmacies; the controller should set the period based on the NHS Records Management Code of Practice and the limitation periods for claims (Limitation Act 1980). - Accounting records: 3 years (private company) or 6 years (public company) (Companies Act 2006, s.388).

Destruction

Pharmacy patient identity data

Data details


Supplementary scheme membership number and reimbursement raterequired
Support raterequired
National Insurance numberrequiredsensitive data
Telephone numberrequired
Genderrequired
Date of birth

Definition

person's date of birth

required
Name and surnamerequired

Data conservation rules

Active base:

3 years from the last dispensing or intervention on the patient's file. No statutory period; the controller should set the period based on continuity of care.

Misuse of Drugs Regulations 2001, reg. 23; Human Medicines Regulations 2012, reg. 253; Companies Act 2006, s.388; NHS Records Management Code of Practice; Limitation Act 1980

Intermediate archiving:

Archived on separate media for the periods required for the relevant registers and records: - Controlled drugs registers and related records: 2 years from the date of the last entry (Misuse of Drugs Regulations 2001, reg. 23). - Prescription-only medicines register (private prescriptions, emergency supplies): 2 years (Human Medicines Regulations 2012, reg. 253). - Other patient and dispensing records: no single statutory period for community pharmacies; the controller should set the period based on the NHS Records Management Code of Practice and the limitation periods for claims (Limitation Act 1980). - Accounting records: 3 years (private company) or 6 years (public company) (Companies Act 2006, s.388).

Destruction

Prescriber's identity

Data details


Conventional situationrequired
Specialty

Definition

Medical Specialty

required
Identification numberrequired
name

Definition

Name of the person

required

Data conservation rules

Active base:

3 years from the last dispensing or intervention on the patient's file. No statutory period; the controller should set the period based on continuity of care.

Misuse of Drugs Regulations 2001, reg. 23; Human Medicines Regulations 2012, reg. 253; Companies Act 2006, s.388; NHS Records Management Code of Practice; Limitation Act 1980

Intermediate archiving:

Archived on separate media for the periods required for the relevant registers and records: - Controlled drugs registers and related records: 2 years from the date of the last entry (Misuse of Drugs Regulations 2001, reg. 23). - Prescription-only medicines register (private prescriptions, emergency supplies): 2 years (Human Medicines Regulations 2012, reg. 253). - Other patient and dispensing records: no single statutory period for community pharmacies; the controller should set the period based on the NHS Records Management Code of Practice and the limitation periods for claims (Limitation Act 1980). - Accounting records: 3 years (private company) or 6 years (public company) (Companies Act 2006, s.388).

Destruction

Data subject (1)

A data subject is any person whose data is collected, retained or processed by the data processing. e.g. In a recruitement process, any candidate for a position proposed in recruitement management process

  • Other

Created at:07/08/2023

Updated on:10/05/2026

License: © Creative commons :
Attribution / Pas d'utilisation commerciale
CC-BY-NC AttributionPas d'utilisation commerciale

Nb using:13


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