Pharmacies: medication files and retention periods
A pharmacy manages an unusual combination of files: medical (dispensed medicines, contra-indications, user history), fiscal (claims to the health insurer) and operational (BIG entries, KNMP affiliation, orders). Several laws apply to the retention periods in parallel: the Medicines Act (Geneesmiddelenwet), the WGBO, the AWR and the Health Insurance Act. This article lines up the periods and describes the right route for destruction.
Which data are retained?
- Medication dispensing administration: what, when, to whom, on which prescription.
- Prescriptions: the physical or digital instruction from the prescriber.
- Patient files: medication overview, contra-indications, user history.
- Claims files: communication with the health insurer.
- Compounding administration: pharmacy compoundings with raw-material tracing.
- Personal data BSN: required for health-insurance linking.
The relevant retention periods
| Category | Period | Law |
|---|---|---|
| Patient file (medication overview) | 20 years from last action | WGBO art. 7:454 BW |
| Compounding administration | 15 years | Medicines Act art. 18 |
| Medicines dispensing | 15 years | Medicines Act |
| Prescriptions (paper) | 15 years | Medicines Act |
| Claim to health insurer | 7 years (tax) up to 10 years (claim litigation) | AWR + Zvw |
| BIG log data | 3 years (guideline) | Wet BIG guideline |
| BSN-bearing files | Follows healthcare term | Wbsn-z |
For BSN-specific attention, read BSN in old administration.
When does what have to go?
The longest period is usually 20 years (patient file, WGBO). That seems long, but for an average pharmacy it still produces a steady stream of documents that have passed the 20-year line:
- Per calendar year, files of people whose last action was in that year.
- Plus files of deceased patients (for whom the term does not automatically end).
- Plus claims older than 7 years (fiscally free).
The annual clean-up is therefore relevant. Read closing the archive audit-ready.
Destruction method
Pharmacy files demand the highest DIN level that is reasonably achievable:
- DIN P-5 minimum for the paper archive.
- P-6 to consider for BSN-bearing files and patient files.
- Hardware: pharmacy information system backups, old HDDs from pharmacy PCs. DIN H-5 or H-6.
- Optical: old backup CDs (read destroying CD, DVD and Blu-ray) at DIN O-5.
For patient files in healthcare institutions the bar is strict: the same level as hospital files. A pharmacy is a healthcare provider under the WGBO.
On-site destruction
For pharmacies, on-site destruction is the recommended route. Reasons:
- No external transport of files containing BSN and medication history.
- Visual confirmation for the pharmacist.
- Supports KNMP audit and municipal inspections.
- Short chain of custody (read chain of custody from archive to shredder).
Working with the GP practice
Pharmacies located in a health centre often share archive space with a GP practice. A joint destruction run can be cost-efficient, provided the streams appear separately on the certificate. For the WGBO context of healthcare files, read WGBO 20 years for patient files.
Pharmacy compoundings and raw-material tracing
The Medicines Act requires tracing of own compoundings for at least 15 years. Not only the prescription file, but also the work protocols, weighing reports and QA documents. Keep these in a separately traceable system. Destroy only after the 15-year line.
Hardware in pharmacies
- Pharmacy information system server: often through the supplier; ask for a NIST 800-88-compliant process at replacement.
- Workstations with point-of-sale system: HDD out at lease end.
- Prescription scanner buffer: may contain persistent copies.
- CCTV footage: 4 weeks under the AP guideline. Read CCTV footage retention period.
Documentation
- Records of processing with retention periods per category.
- Certificate of destruction per job; keep 5 years.
- Processor agreement with the destruction supplier.
- Align with KNMP audit requirements.
On-site destruction at DIN P-5 or P-6 for pharmacies.
We visit pharmacies in Noord-Holland for annual destruction of patient files, prescriptions and compounding administration.
Request a quotePharmacy archive ready for a clean-up? Email us via desnipperaar.nl with an estimate of volume and the desired DIN level.