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Relationship with other members of the healthcare team CHAPTER 14
daily basis and with far more ease of contact than
the community pharmacist has with the community GP. When dealing with the junior doctors and
nursing staff in hospital the pharmacist will have a
teaching/supportive role while assuming an advisory role on the use and side-effects of drugs when
dealing with the more experienced consultants.
Hospital pharmacists will also be in contact with
other professionals with regard to discharging
patients into the community, such as social workers, physiotherapists, occupational therapists, dentists and the local drug misuse team. Within the
hospital environment the pharmacist may have to
become involved with the various hospital committees, e.g. drug safety, ethics, general administration,
formulary, etc. and interact with a range of professional as well as administrative roles. In addition,
hospital ph armacists will be in contact with community pharmacists to ensure a seamless supply of
medicines to those patients discharged from hospital on specialized drug regimens.
The changing role of the pharmacist as discussed in
Chapter 1 has made it even more important that the
pharmacist depends on their healthcare team to free
up the time to allow them to deliver the various services required by the new pharmacy contracts. The
pharmacist is moving further away from the traditional role of being ‘counters and pourers and stickers
and lickers’ to advising patients and customers on
their medicines, conducting medicine use reviews
(MURs), promoting health advice, etc. (see Chs 5
and 47).
entitled ‘Assist in the sale of OTC medic ines a nd
provide information to customers on symptoms
and products’ and ‘Assist in the supply of prescribed items (taking in a prescription and issuing
prescribed items)’.
There is a requirement that the course should
be completed within a 3-year time period and that
the member of staff should be enrolled on such a
course within 3 months of starting their role.
The following training programmes for medicines
counter assistants/healthcare assistants have been
accredited for the RPSGB by the College of Pharmacy Practice:
*
AAH Retail Pharmacy
*
Boots the Chemist
*
Buttercups Training
*
CMP Information Ltd.
*
Moss Chemist
*
National Pharmacy Association
*
Superdrug
*
Tesco Stores Ltd.
Medicines counter assistants/healthcare assistants
will primarily be found in community pharmacy in
residential areas and supermarkets. Their training
usually takes the form of ‘workbook-led on-the-job
learning’, meeting the above requirements for accreditation with the pharmacist acting as the tutor. This
allows the relationship to develop and the pharmacist
to realize the potential and limitations of these members of staff.
The community healthcare team
Medicines counter assistants/
healthcare assistants
From 1 July 1996 it has been a professional requirement that each member of staff whose work
in a pharmacy will regularly include the sale of
medicines must have compl eted a course or be
undertaking an accredited cours e relevant to their
lineofwork.TheRoyalPharmaceuticalSocietyof
Great Britain’s (RPSGB) requirement is that the
courses should cover the knowledge and understanding associated with units 2.04 and 2.05
of the Scottish/National Vocational Qualification
(S/NVQ) level 2 in Pharmacy Services. These are
Dispensing/pharmacy
assistants
The training required is much more in-depth than
for the medicines counter/healthcare assistant to
reflect the variation in role and responsibilities.
The job title will vary depending on the sector of
pharmacy the person works in and indeed the company/business they work for – dispenser, dispensing
assistant, pharmacy assistant, assistant technical officer, etc. Whatever their title or sector of pharmacy they are working in, what they all have in
common is that they are working under the supervision of the pharmacist.
From 1 January 2005 there is the professional requirement that these dispensing/pharmacy assistants
are competent in the areas in which they are working
to a minimum standard which is equivalent to the new
139
SECTION TWO Governance and good professional pharmaceutical practice
Pharmacy Services S/NVQ level 2 qualification or are
undertaking such training.
This applies to staff working in the following areas:
*
As for the medicines counter or healthcare
assistants with units 2.04 and 2.05 qualifications
(see above)
*
The assembly of prescribed items including the
production of labels
*
Ordering, receiving and storing pharmaceutical
stock
*
The supply of pharmaceutical stock
*
Preparation for the manufacture of pharmaceutical
products, including aseptic products where
relevant
*
Manufacture and assembly of medicinal products,
including aseptic products where relevant.
To fulfil this requirement a training programme
relevant to the job needs to be completed within
a 3 -yea r time period and the member of staff
should be enrolled on such a course within 3
months of starting their role. If a member of staff
has not undertaken such a course but they fulfil the
requirements of the ‘grandparent clause’ and a declaration of competence has been sent by their supervising pharmacist to the RPSGB during the
‘grandparenting’ period, then the member of staff
does not need to undertake further study to remain
a dispensing/pharmacy assistant. (The ‘grandparent
clause’ recognizes that existing staff may already
have completed an appropriate course and/or have
relevant experience.)
The dispensing/pharmacy assistant is a key member of the healthcare team as they free up the pharmacist from the assembly processes involved in the
dispensing of prescriptions.
Pharmacy technician
A pharmacy technician is someone who has undertaken a course that provides them with an S/NVQ Pharmacy Services level 3 qualification. The ‘pharmacy
technician grandparent clause’ has allowed a number
of other qualifications, formerly recognized as pharmacy technician qualifications, to be acceptable for
registration purposes. Further details on these qualifications can be verified with the RPSGB.
Once qualified, the pharmacy technician may
choose to join the register of technicians. This was a
voluntary register opened by the RPSGB in January
2005 but registration is now a requirement for those
wishing to use the title ‘pharmacy technician’ (this
title is protected in law). By doing so they are bound
by the Code of Ethics and must participate in continuing professional development – the same requirement as for pharmacists.
The pharmacy technician may work in hospitals,
community pharmacy, health centres, primary care
trusts, prisons and the armed forces and in the pharmaceutical industry. We will focus on community and
hospital pharmacy.
Community pharmacy
Pharmacy technicians are required to make up the
prescriptions issued by doctors. These are then
checked by the pharmacist both for accuracy and to
make sure that the dosage and treatment are safe for
that patient, i.e. a clinical check.
The role of the technician involves:
*
Reading prescriptions and translating doctor’s
instructions
*
Counting tablets and measuring specific quantities
of liquids
*
Preparing accurate labels for medicines on the
computer system which usually inform the patient
what the drug is and how to use it
*
Selling other medicines and other complementary
preparations
*
Referring to the pharmacist when appropriate
*
Small-scale or individual preparation of
extemporaneous products as requested by the
doctor which are not supplied as ready to use by
manufacturers
*
Maintaining and managing stock within the
pharmacy
*
Record keeping and audit
*
Being aware of the legal requirements relating to
prescribing and supply of medicines.
As can be seen there is considerable overlap with the
dispensing/pharmacy assistant role, but with additional responsibilities.
The pharmacy technician may choose to become
an accuracy checking technician (ACT), which would
require them to undertake a further period of study
and development of a portfolio of evidence to demonstrate their competence in this area. The technician
must have successfully checked 1000 items error free
in a defined period of time (usually 4 weeks) while
keeping a diary of all items checked and any errors
made while checking or dispensing and completing
140
Relationship with other members of the healthcare team CHAPTER 14
any assignments required by the employer. They then
have a final assessment which requires them to check
the accuracy of a set amount of prescription items
under timed conditions.
The checking technician plays an invaluable role.
They will accuracy check the prescriptions once the
pharmacist has clinically checked them. This has not
only been shown to be more accurate than pharmacist
checking but also, more importantly, it frees up the
pharmacist to get on with the other new roles that are
emerging, such as carrying out MURs in England,
being involved in the electronic minor ailment scheme
(eMAS) in Scotland, supplementary and independent
prescribing, etc.
Hospital pharmacy
The work in the hospital pharmacy setting for a pharmacy technician has many similarities to that in the
community sector. However, the work has greater
variation due to the different areas for care within
hospital. These include:
*
Visits to the wards to take orders for medicines
*
Preparation of radioactive materials or working on
clinical trials
*
Use of computers and robotics for purchasing,
stock control and dispensing
*
Production of medicines in special sterile units
requiring specialist clothing and working in a sterile
environment
*
Working in manufacturing or production units in
some hospitals.
Hospital pharmacy has also had the role of the ACT in
place for a number of years now and the criteria for
this role are similar to those described above for the
community role.
Other members of the
pharmacy team
to become a pharmacist they are required to undertake a period of training, usually 1 year within a
pharmacy setting, either community or hospital.
Some may choose to enter industry and carry out
a split placemen t between this sector and hospital
but these only account for a small number of the
graduates. At the end of the training period the
graduate has a registration examination to undertake and pass before they can enter the pharmacy
profession. During the training year the preregistration pharmacy trainee becomes a valuable
member of the team while turning their university
knowledge into practical skills within the pharmacy.
It is important that at this time the trainee has the
end goal of pharmacist in mind and does not become absorbed into the day-to-day tasks of the job.
The p re-registration pharmacy trainee is given guidance from their tutor throughout this period.
Pharmacy undergraduates join the pharmacy team
at any time depending on the needs of the pharmacy
setting. Some may work on a part-time basis at weekends, others for a period of time during the university
breaks to gain experience in the different areas of
pharmacy and decide where they will complete their
pre-registration training.
Role of the pharmacist in teamwork
The role of the pharmacist, both in the primary and
secondary care setting, is changing. No longer can the
pharmacist work in constant isolation: they must learn
to become integrated members of both their immediate and extended teams, and so it is essential for the
pharmacist to recognize that team leading, delegation,
negotiation and teamworking are essential skills that
they must possess.
Leadership
There are other people who can play an important role
in the pharmacy team but they are not present in
every pharmacy team at all times. These are preregistration pharmacy trainees and also pharmacy
undergraduates either taking part in a period of
vocational placement or working on a part-time basis
in the pharmacy setting.
Pre-registration pharmacy trainees will have
completed 4 years of study at university and obtained an accredited de gree in pharmacy. In order
There have been a lot of studies carried out to determine what it is exactly that makes good leaders. The
majority of these studies lead to the conclusion
that leadership is about the behaviour of the leader
first and the skills that they possess second. It is
about recognizing that people need to trust and respect you before they will listen and act on what you
ask them to do.
In any one environment there can be a number of
different teams working together, e.g. in the hospital
141
SECTION TWO Governance and good professional pharmaceutical practice
setting or the community setting, and sometimes one
particular team will outperform the others. Why is
this?
In all cases it is attributable to the person leading
the team and the fact that they possess such qualities
as integrity, honesty, humility, courage, commitment,
sincerity, passion, confidence, positivity, wisdom, determination, compassion and sensitivity. This makes
their staff willing to go that ‘extra mile’ for them.
Some people are naturally born with these behaviours
already well developed but others, recognizing that
these behaviours are important, can develop this side
of their behaviours to achieve great leadership qualities.
A good leader will be able to use a number of
different leadership styles depending on the situation
they are faced with. Again some people have a dominant style of leadership, but to be truly great they
need to look at all the other styles of leadership and
develop these also.
As a pharmacist it is important to recognize that
no matter what area of pharmacy you work in you
will always be looked upon as the leader of that
team, and it is crucial to know your own strengths
and weaknesses and build on these. This is where
continuing professional development (CPD) really
comes into play. This is discussed in more detail in
Chapter 10. CPD is the process whereby the phar-
macist can effectively identify and plan what they
need to address to develop their leadership qualities or indeed any area that will benefit their professional career.
The correct behaviour, especially towards your
team, is the key to being an effective leader and the
following are some tips towards being respected as a
leader:
*
Honesty and integrity – without this no one in your
team will respect you
*
Never shout at people no matter how angry you
get as this only serves to break down the
relationships built with the team (‘praise loudly,
blame softly’ – Catherine the Great 1729–1796)
*
Always lead by example – if you are not seen to
be ‘doing’ then the message that sends to others is
that it is not important to be hard working
*
Recognize when you need to work with your
team to get tasks done – nothing should be beneath
you and you should never be afraid to ‘get your
hands dirty’
*
You need to treat all members of the team fairly
and based on merit, not singling people out
because th ey like the same football team, for
example
*
On the other hand you need to be seen to be dealing
with any bad or unethical behaviour of team
members. Ignoring this type of behaviour is giving
out the message that you condone it
*
Listen to your team and try to understand their
point of v iew – it is sometimes important to
place yourself in someone else’ sshoestosee
their point of view. This does not mean you have
to agree with everything but it w ill give you a
better understanding of where they are coming
from
*
Accept the responsibility for when things do not go
as planned – do not blame the team or individuals
within the team
*
Always give credit where credit is due even for your
own successes, because you would never have got
there without your team behind you (‘Behind an
able man there are always able men’ – Chinese
proverb)
*
Provide support for the team so they know
that they can trust you to act in their best
interests
*
Always ask for opinions and i deas from the team
so that they feel that they are involved in the
decisions you may make, especially if things need
to change. It is easier to handle change if the
team members have been involved from the
beginning
*
If you agree to do something then make sure you
follow through – do not make empty promises as
you will quickly lose the trust of your team
*
Encourage the development of your team, giving
them responsibility for certain tasks that stretch
their abilities without putting undue pressure on
them
*
Be positive, even about things that have gone wrong
– we can always learn from this and make things
better the next time
*
Have fun in the workplace – your staff should feel
happy in the work they do and in the environment
they work in as they spend so much time there;
there is no point being miserable
*
Smile!
*
Remember why you are all there – what is the job in
hand?
*
Seek feedback from others to find ways you can
develop and improve your skills and behaviours and
recognize that we never stop learning.
142
Relationship with other members of the healthcare team CHAPTER 14
No pharmacist can do all the tasks themselves so it is
essential that they recognize that many tasks need to
be delegated to the other team members.
Delegation
Good delegation will save you time, will develop your
team and generally motivates all involved. It is not just
a technique to free up time. Poor delegation will lead
to frustration, demotivation among your team and
failure of the task(s) involved so it is essential that
delegation is effective.
When delegating tasks one should follow the
SMARTER mnemonic. To ensure success on completion then all delegated tasks must be:
*
Specific – if it is unclear what the task is, then how
can it be completed effectively? Can this task, in
fact, be delegated?
*
Measurable – you have to be able to measure when
the task has been completed to know that success
has been achieved. What is the end goal or measure
to demonstrate this? This needs to be clearly
defined.
*
Agreed – both parties must be in agreement to the
task otherwise this is where frustrations and
resentments start to form. Is the individual or team
capable of doing the delegated task? Do they
understand the bigger picture and where they fit
in?
*
Realistic – if the task is not achievable, either
because of timescales or lack of the necessary skills
or resources, then this will only serve to demotivate
the person involved.
*
Timebound – the task should not be so great that it
cannot be completed in the timescales agreed, so
this comes back to the task being realistic. If it is an
ongoing task then specific review dates need to be
in place and adhered to and agreed outcomes
clearly defined, e.g. generation of reports, targets
reached, etc.
*
Ethical – you should not be asking your team to
carry out a task that goes against their professional
or moral ethics.
*
Recorded – this is important to cel ebrate the
successes of your team if you keep a record of
the tasks that have been completed and it also
helpstolearnfromtasksthathavenotbeen
completed and enables you to provide
constructive feedback to your team when things
do not go as planned.
It is extremely important for the pharmacist to be
able to delegate various tasks within the pharmacy
to suitably trained persons because it is no longer
cost-effective for the pharmacist to be carrying out
tasks that others are more than qualified to complete.
Thus this frees the pharmacist to get on with the job
they were educated at university to do and leads to job
satisfaction for all staff involved.
In order to get the members of the immediate and
extended teams on board the pharmacist has to be
aware of, and if necessary develop, their negotiation
skills.
Negotiation
Negotiation is something that we do all the time in
and out of the working environment and maybe do not
realize it, e.g. deciding what to see at the cinema,
where to go out to eat, where to go sightseeing on
holiday, what shift someone should work and for how
long, etc.
Negotiation is usually considered as a compromise between people to get what we want. To be
really effective in the team environment the compromise should allow both parties to be satisfied
withtheeventualoutcome.Theonlytimeyou
may want to consider the win–lose negotiation is
if you do not need to have an ongoing working
relationship with the other party. This is something
thatisgoingtobeveryunlikelyinthepharmacy
setting. If the pharmacist always negotiates to ‘win’
then the working relationship within the team will
eventually break down and the working environment will suff er. Ultimately patient care deterioratesasnooneworkstogether.
Communication is the key link that will be used to
negotiate and as such can be in a variety of ways – face to
face,inwriting,overthetelephone,etc.(seeCh. 13).
Body language is thus another area that the pharmacist
may wish to develop as body language accounts for over
90% of a conversation.
For successful negotiation to occur the following
should be considered:
*
Goals – what do you need to get from the
negotiation and do you know what the other
party also wants? You need to be really clear
why you are negotiating and think about what
you will accept before entering into the
negotiation.
*
Separate people from the problem – do not get
caught up in personalities and relationships and
143
SECTION TWO Governance and good professional pharmaceutical practice
focus on what the actual issues are. It will be a lot
easier to justify a decision reached if the results are
based on objective criteria.
*
Generate a variety of possible solutions – no matter
how ridiculous they might first sound – before
going on to decide the best option to meet
everyone’s needs. Sometimes asking the other
party ‘What do you think?’ might allow them to
actually come up with a solution that you had not
thought about but which fulfils everyone’s needs.
Pharmacists in both the primary and secondary care
sector are now required to work very closely together to deliver the government targets for access
to health care, provision of services outside normal
working hours in addition to the range of services
and roles detailed in the new pharmacy contracts.
As men tioned, pharmacists are depend ent on the
skills of their immediate teams to be able to fulfil
these new roles and have to be able to demonstrate
that they meet the clinical governance requirements. This requires a great deal of teamwork both
within the immediate teams and the extended
teams.
Conclusion
Pharmacists may work well in their immediate teams
but if they are to embrace the changing role of pharmacy and health care then they need to extend their
teamworking across a wide variety of healthcare professionals and embrace all the skills highlighted above.
It is essential that pharmacists start to maintain a
formal record of all their contributions and interactions within the wide variety of teams to demonstrate
their invaluable contribution to patient care.
KEY POINTS
*
To meet their professional responsibilities
pharmacists need to work with a wide variety of
other healthcare staff
*
A range of communication skills is required to be
effective teamworkers together with the ability to
respect, help, share and collaborate with others
*
A healthcare team will be either an immediate or an
external team
*
In community pharmacy, the immediate team will
be staff trained to carry out specific responsibilities
*
External team members could include other
pharmacists, doctors, nurses, health visitors,
physiotherapists, drug misuse teams, dentists,
chiropodists, opticians and administrators
*
The exact role which the pharmacist has will
depend on relative experience and knowledge
*
There are detailed requirements for qualifications
required of different levels of pharmacy support
staff
*
Some pharmacists will have to assume leadership
roles, which requires a wide range of skills, some of
which may have to be learned as part of CPD
*
Delegation is often a necessity but has to be
effective and achievable. The mnemonic
SMARTER can be a useful guide
*
Negotiation is frequently part of making progress in
a healthcare team
144
Chapter Fifteen
Record keeping
Mary Zargarani
15
STUDY POINTS
*
The types of records pharmacists keep and why
they keep them
*
How the law and the code of ethics affect
pharmacists’ record keeping
Introduction
Pharmacists are required to keep a number of different types of records within the pharmacy, the
majority of them being legally required and some
as good practice. With the evolving role of pharmacists, the need for and types of records to be kept are
ever increasing. The aim of this chapter is to consolidate the different aspects and issues around record
keeping in the pharmacy.
Why keep records?
There are many things that need to be recorded in the
pharmacy. They can be categorized into three main
groups; however, it should be noted that there can be
considerable overlap between these groups:
*
Records of supply, e.g. controlled drug register
entry
*
Clinical governance records, e.g. dispensing
incident reporting and audit
*
Consultation records, e.g. giving advice on weight
loss to a diabetic patient.
Aside from the fact that many of these records are
required legally or as part of the pharmacy’s contractual requirements with the NHS, there may be dif-
ferent reasons why each type of record is made. The
traditional records of supply and clinical governance
are mainly kept for the purpose of invoicing and to
provide an audit trail for monitoring standards, improving quality and ensuring safety.
Pharmacists may well be the only healthcare profession in the UK that has not documented their contribution to the health of the nation over the years.
Therefore, unless the pharmacist develops the skills
for and embraces record keeping, their role and future
roles may be called into question. The reasons for
record keeping have now taken on a new importance.
Documentation can be used as justification for a pharmacist’s decisions and judgment in difficult situations. Also pharmacists, like other professionals,
have to justify their very role within the community.
The records provide evidence and aid decision making. In addition, record keeping is an important form
of communication between pharmacists and other
healthcare professionals and can ensure continuity
of care for a patient.
What to record?
In the majority of cases the information that should be
recorded will be specified, or there may be a specific
form to fill in. The traditional records of supplies and
clinical governance are generally specified which
makes this information relatively easy to record.
The problem arises when there are no specified procedures to tell pharmacists what to record, e.g. consultation records. This is a relatively new area for the
pharmacist. Before the changes to the pharmacy contract in 2005 they were not required to record
SECTION TWO Governance and good professional pharmaceutical practice
Box 15.1
Guide to the type of information to record in a
consultation record
*
Patients’ identification details
T Title
T Name
T Address
T Age/date of birth
T Telephone number
T Identification numbers, e.g. NHS number,
patient medication record number
T Medical conditions
T Current medication
*
Date
*
Time
*
Who was involved, i.e. the pharmacist, GP, patient,
nurse, etc.
*
What was involved and the reason, e.g.
identification of an overdose
*
Outcome or proposed action, e.g. a dose
reduction
*
Possible follow-up
*
Information sources used
*
Name of person making the entry, if not the person
involved
interactions with the public and information was provided on a daily basis without it being logged.
Consultation records should be written so that
others can use the information provided and realize
the same outcome as the person that made the record.
The level of information recorded will depend on the
situation. All records need to be concise, organized,
factual and legible, and abbreviations should be
avoided if possible unless clear and established. Beware of recording personal views and opinions about
patients and their behaviour, unless it is relevant to the
record, as according to the Data Protection Act (DPA)
1998 patients have the right to request their records.
The list in Box 15.1 indicates the type of information
to record if not specified.
Barriers to record keeping
There are two main barriers to record keeping, namely time and knowledge. The traditional records of
supply and, to some extent, clinical governance are
generally well kept and the time taken to carry out the
record is generally already built in to the procedures
for the normal working day. Knowledge of the record,
the procedure and location are also generally not an
issue, as again the pharmacist is accustomed to the
procedure. The problem arises with newer consultation records and some aspects of clinical governance
that are not carried out regularly.
Knowing how to make the record can be a problem, especially for consultation records of which pharmacists in many cases will have no experience. Time
can be a major issue for recording consultations, especially if the contact was opportunistic, which is
often the case with the advice the pharmacist may
provide. Is it feasible to record all of the information
the pharmacist provides to patients on a day-to-day
basis? The pharmacist cannot be expected to know
the name of every person they give advice to concerning over the counter medicines, yet it may be necessary to record this interaction.
The sooner the record is made the better. Forgetting to record an opportunistic consultation is
more likely if the pharmacist intends to ‘come back
to it later’. It may be helpful to have a logbook where a
note can be kept and recorded appropriately later.
Other healthcare professionals, such as GPs and
nurses, leave themselves time after a consultation to
record it straight away. Pharmacists may need to look
at how these other professionals have overcome the
barriers to record keeping in these new areas.
The future of records
The drive to keep records electronically is becoming
more and more apparent. The benefits of keeping
electronic records surround the potential for shared
information between healthcare professionals and
external audit purposes. For example, the Royal
Pharmaceutical Society of Great Britain (RPSGB)
inspectors or police may monitor an online controlled
drug (CD) register without needing to attend the
premises.
The advancement of electronic transfer of prescriptions (ETP) has led to the debate over the best
method of access for pharmacists to view full patient
medication records. This will enable the pharmacist
to be better placed to intervene when necessary and
may avoid unnecessary interruptions to the doctor.
Medicines use reviews (MURs) can potentially be
carried out more effectively and may reduce the
likelihood of making recommendations that have already been tried or are inappropriate. Pharmacist
146
Record keeping CHAPTER 15
prescribing will definitely require better access to
records. Pharmacists are often required to make decisions without the full patient history. Improved access
to records will save time and provide more efficient
and effective outcomes for patients. Likewise other
healthcare professionals involved in patient care need
to know what input the pharmacist has made.
The Data Protection Act 1998
The Data Protection Act (DPA) was first introduced
in 1984 as concern grew over the amount of personal
information that was being held on computer. This act
related only to data held electronically but in 1998
was updated to the current DPA which applied to data
held in any format. Now in most cases the individual’s
permission must be sought before personal information can be stored, processed or used for direct marketing. Personal information is defined as any
information that can be used to identify a living individual, such as name, address, date of birth, etc. Interestingly, there is no lower age limit that applies to
the DPA, so as long as a child can understand their
rights, their consent must also be sought.
The DPA requires explicit consent before the processing of personal data can take place. This is not the
case for sensitive personal data when the processing is
necessary for medical purposes. For consent not to be
required, a healthcare professional or their staff, including pharmacists and their dispensing staff, must
undertake the processing. Sensitive personal data
relates to any information including opinions relating
to the physical or mental health or condition of the
individual. Processing of information means the use of
this information in virtually any way, including destroying the information. All systems used to store information will need to be registered with the Information
Commissioners Office which enforces the DPA, and
this now includes electronic and written information.
In the pharmacy, the patient medical record (PMR)
system, prescription only medicine (POM) register,
controlled drug (CD) register and any other method
of data collection will need to be registered.
There are eight principles within the DPA. We will
look at each principle in turn and how it applies to
pharmacy.
1. ‘Personal data shall be obtained and processed
fairly and lawfully and shall not be processed at all
unless certain conditions are met’
Generally permission must be sought from the individual before records are kept and they should under-
stand why the data are being collected, except for
sensitive personal data which is included in PMRs
which can be recorded without permission.
2. ‘Personal data shall be obtained and processed for,
or in ways which are not incompatible with, one or
more lawful purposes’
Data cannot be collected without a lawful purpose.
In the case of PMRs, c linical governance principles
and the pharmacy contract require pharmacists to
maintain PMRs. Guidance taken from the RPSGB
states that if a patient requests the removal of their
data from the PMR system and cannot be persuaded otherwise, they should be asked to sign a
disclaimer. This does not apply to records made in
the POM register or CD register as this is a legal
requirement.
3. ‘Personal data shall be adequate, relevant and not
excessive in relation to that purpose or purposes’
PMRs should only contain information relevant for
the purpose, e.g. notes on a patient’s medical conditions and allergies would be relevant but information
about their preferred brand of toothpaste would not
be – unless it had implications for their medical care.
4. ‘Personal data shall be accurate and kept up to
date’
The data should be as accurate and as current as possible. Be aware that some of the information may
change, such as the patient’s exemption status, address, title, etc.
5. ‘Personal data shall not be kept for longer than
necessary’
If no longer required, generally data should be deleted
or destroyed. In the case of PMRs, they may be kept
for as long as necessary; however, with respect to the
Consumer Protection Act where the PMR is the only
record of supply, the record should be kept for 13
years.
6. ‘Personal data shall be processed in accordance
with the rights of the data subject (the individual)
under the act’
The individual’s rights are as follows:
*
To know that their data are being processed
*
To know exactly what data are kept, why and
who will see them
*
To prevent their data being used for marketing
purposes
*
To seek criminal proceedings or sue for
compensation if their rights are disregarded
*
To be provided with the details of the data being
held on them within 40 days of the request
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SECTION TWO Governance and good professional pharmaceutical practice
*
The identity of the person requesting it must be
verified as the individual himself or herself.
7. ‘Personal data shall be protected against
unauthorized or unlawful processing and against
accidental loss, destruction or damage’
Only people that need access should have access.
Dispensing staff will need access to PMR records to
do their job, but a counter assistant would not. Staff
as a doctor’s prescribing habits. In addition to the
DPA, confidential information must be protected
against improper disclosure during storage, removal,
receipt or transfer. Also access control and data encryption are necessary. All confidential information
must be disposed of so the information is irretrievable; in most pharmacies they will have a confidential waste bin.
with access to any personal data should also be trained
with respect to the DPA.This also has implications for
Records of supply
the layout of the dispensary workspace, in that customers should not be able to view the computer screens.
All information must be backed up appropriately. Information can be passed on to others if the individual
consents but this must be clarified. There are circum-
The major examples of supply records made in the
pharmacy and where they are kept are described below (this is not an exhaustive list).
stances where information can be disclosed to a third
party without the individual’s consent. These include
POM register
the following:
*
Where a patient’s health or age makes them
incapable. In such cases it may be necessary to get
someone else such as a parent, guardian or carer
to make the decision to disclose information.
However, information about an adolescent should
not normally be disclosed to parents
*
The third party is empowered by statute to require
the disclosure
*
Requested by a judge, coroner or crown
prosecution office
*
To a police or NHS fraud investigation officer who
request in writing, confirming disclosure is
necessary to prevent, detect or prosecute a serious
crime
*
When it is necessary to prevent serious injury or
damage to the patient, a third party or the public.
8. ‘Personal data shall not be transferred (with
certain exceptions) outside the European
Economic Area unless the recipient country
operates the same controls on data protection as
applies within the EEA’
The prescription only medicine (POM) register is
possibly the most longstanding means of recording
within the pharmacy. It is primarily used for recording
the supply of POMs as a legal requirement of the
Medicines Act 1968, but is also used traditionally by
the pharmacist to record significant incidents occurring in the pharmacy for future reference. They are
found in both the community and hospital pharmacy
and must be kept on the premises for the specified
time frame for the record made, generally 2 years
from the date of last entry. They are used to record
every sale or supply of a POM unless it is with relation
to an NHS prescription or a prescription for a contraceptive. A record also is not necessary if the supply
is by way of wholesale dealing where the invoice is
retained or if a separate record has already been made
in the CD register.
The supply of a POM may take many forms and
each will require different information to be entered in the register and to be kept for a specified
duration of time. This information may be found in
the current edition of the Medicines, Ethics and
Practice guide (MEP). The following list includes
Confidentiality
commonly made records of supply in the POM
register:
*
Confidentiality is protected by scores of pieces of
legislation such as the DPA, the Human Rights Act
1998 as well as by common law. The NHS also has
its own code of practice, as do pharmacists, and
pharmacists must have systems that conform to all
of the above. Confidential information includes
both personal and medical details of patients and
also information about other NHS employees such
Private prescriptions
*
Emergency supplies at the patient’s or doctor’s
request
*
Signed orders or supply to a person authorized to
sell, supply or administer POMs
*
Veterinary prescriptions (NB: it is not specified
where the record is to be made but is traditionally
made in the POM register).
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