In the April 5, 2023, edition of the Link, ACP shared amendments to the Pharmacy and Drug Regulation (PDR), which included a requirement that pharmacy licensees ensure “a criminal record check from all unregulated individuals engaged by the pharmacy who support or provide assistance in providing a restricted activity or the delivery of a drug to a patient.” (s25(e.1))
ACP knows that licensees prioritize the integrity and security of their drugs, patient records, and pharmacy operations. Ensuring that all unregulated individuals, including current and future employees, who work with a pharmacy have completed a criminal record check is a way of achieving this priority.
Licensees and proprietors must define their human resource policies and procedures, including the frequency and details about how criminal record checks are to be completed. Licensees should review the roles and responsibilities of each unregulated individual who works with the pharmacy team and determine which unregulated individuals support or assist in providing a restricted activity or the delivery of a drug to a patient.
This requirement from the PDR applies only to unregulated individuals, as regulated members (pharmacists and pharmacy technicians) must periodically supply ACP with a current criminal record check as part of registration processes.
The results of a criminal record check of unregulated staff may or may not affect the employment status or role of that individual, depending on the details of the results and how it relates (or does not relate) to the individual’s role in the pharmacy. Licensees must consider the information gathered in the criminal record check and make a decision that is reasonable to maintain the security and integrity of the drugs, patient records, and operations within the pharmacy. If a licensee’s decision affects the employment of an individual, the licensee is encouraged to seek advice from a human resource professional.
In conclusion, licensees are ultimately responsible for the security of drugs and patient records at the pharmacy. While this regulation only applies to unregulated individuals who support the pharmacy team to provide a restricted activity or deliver a drug to a patient, a good practice would be to extend this to all unregulated individuals who have access to the dispensary and the drugs and patient records stored there. In that context, consideration should be given to both employees and any individuals contracted to provide any service requiring them to be in the dispensary.
