Standards of Good Professional Practice
Council sets standards for internet pharmacy
The Council of the Royal Pharmaceutical Society has published a document laying down standards of good professional practice for those who wish to provide pharmaceutical services via the internet.
The new standard is set out below, with an introduction agreed by the Council's ethics working party. It will be incorporated into the next edition of ‘Medicines, ethics and practice: a guide for pharmacists', which is due to be published later this month. It will be added to the Appendix to the Code of Ethics, where it will join the 18 existing standards covering various aspects of professional practice.
It is intended that the standard for on-line pharmacy will be included in the proposed new code of ethics, which was published as a consultation document in September, 1999 (Supplement, PJ, September 18, 1999). Although the official consultation period closed on December 31, 1999, the ethics working party would be glad to receive comments on the proposed new standard. Comments should be sent as soon as possible and should be addressed to the Secretary to the Ethics Working Party, Royal Pharmaceutical Society, 1 Lambeth High Street, London SE1 7JN (fax 020 7582 4279; e-mail hdarracott@rpsgb.org.uk).
The provision of pharmacy services via the internet
For some time the Council has been aware of the development of on-line pharmacy services and has been working to identify the specific issues such developments raise. The Council has decided to publish interim standards identifying the issues to pharmacists offering on-line pharmacy services. These standards will be updated in the light of future developments.
As with all professional services, on-line pharmacy services must be provided within the legislative framework for pharmacy and in compliance with existing professional requirements detailed in the Code of Ethics (see Notes below).
The public is entitled to expect the same high quality pharmaceutical care irrespective of whether the service is provided on-line or face to face on pharmacy premises. At all times pharmacists must act in the best interests of the patient and seek to provide the best possible health care.
The following standards reflect particular issues related to the use of a distant pharmacy that are not reflected in the current requirements for community pharmacies. Where the standards below depart from those in the Code of Ethics these are specific additional requirements applicable to on-line pharmacy services. Other provisions of the code applicable to the services offered must be observed.
Standard 19: Standards for the provision of on-line pharmacy services
19.1 Security/confidentiality
- (i) Pharmacists must ensure that the confidentiality and integrity of all patient information is protected. The standards specified in BS7799 (see Notes below) must be observed.
- (ii) All patient data transmissions must be encrypted to prevent the possibility of access by the internet service provider or any other unauthorised party.
National Health Service patient data must comply with security standards and other requirements determined by the NHS Executive.
19.2. Request for supply of medicines
- (i) Pharmacists providing on-line pharmacy services must advise patients to consult a convenient pharmacy whenever a request for a medicine or the symptoms described indicate that the patient's interests would be better served by a face-to-face consultation.
- (ii) In all cases where a pharmacy medicine is requested or recommended, a questionnaire appropriate to the product must be completed. Advice must be offered to all prospective purchasers of general sale list medicines and vitamin and mineral supplements.
19.3. Information and advice
- (i) All information related to specific products must comply with the marketing authorisation, the patient information leaflet and the Advertising Regulations.
- (ii) Information relating to medicines must include all relevant details of contraindications and side-effects.
- (iii) Non-patient specific health care advice, such as that relating to the treatment of symptoms or specific conditions, first aid, travel precautions, etc, provided on pharmacy websites must be of a high professional standard and the pharmacist assuming professional responsibility for the provision of that advice must be identified.
- (iv) Product recommendations may only be given in respect of individual patients and a record must be kept of the pharmacist assuming professional responsibility for the recommendation.
- (v) Before a patient receives a medicine the pharmacist must ensure that the patient or their carer understands how the medicines are to be administered, and that any appropriate information, advice or counselling is provided. Procedures for dealing with requests for supplies of medicines and/or delivery arrangements must ensure that this occurs.
19.4. Record keeping
- (i) The pharmacy must maintain records for two years of all purchasers of medicines, details of the medicines supplied, and the information upon which the decision to supply a pharmacy (P) medicine was based.
- (ii) Records must be kept to identify the pharmacist authorising every supply of a P or prescription-only medicine (see Notes below) following an e-mail request to purchase.
Notes
Pharmacists are reminded of the following statutory and professional requirements:
- (a) BS7799 is published by the British Standards Institution, 389 Chiswick High Road, London W4 4AL (tel 020 8996 7000; website www.bsi.org.uk)
- (b) Pharmacists offering on-line pharmacy services are reminded to ensure that they have adequate professional indemnity insurance arrangements in place to cover on-line services.
- (c) Use of distant pharmacies increases the risks of forged prescriptions being presented.
- (d) All requirements of the Medicines Act 1968 and Regulations must be complied with, including the requirements for the supplying pharmacy to hold a valid prescription.
- (e) Pharmacists are reminded that they must not supply a Schedule 2 or 3 Controlled Drug against a prescription unless they are acquainted with the signature of the person by whom it purports to be issued and they have no reason to suppose that it is not genuine, or they have taken reasonably sufficient steps to satisfy themselves that it is genuine.
- (f) Pharmacists are reminded that the provision of product information on a web site may constitute an advertisement and the requirements of the Advertising Regulations must be met.