Scope of This Policy

This Privacy Policy applies to:
  – pharmacists, pharmacy technicians, and authorized pharmacy staff using the SafeScripts platform
  – information submitted through the medication incident reporting system.

The Platform is designed to support community pharmacies in documenting medication incidents and near misses as part of medication safety and continuous quality improvement programs.

Applicable Privacy Laws

SafeScripts operates in accordance with applicable Canadian privacy legislation including:
  – Personal Health Information Protection Act
  – Personal Information Protection and Electronic Documents Act

Pharmacies using SafeScripts typically act as Health Information Custodians under PHIPA. SafeScripts acts as a service provider or agent processing information on behalf of pharmacies.
SafeScripts also supports medication safety reporting practices consistent with expectations of the Ontario College of Pharmacists.

Information We Collect

Account and User Information
We may collect information related to platform users including:
  – name
  – professional role (e.g., pharmacist, pharmacy technician)
  – work email address
  – pharmacy affiliation
  – login credentials.

Pharmacy Information
We may collect organizational information about participating pharmacies, including:
  – pharmacy name
  – pharmacy location
  – pharmacy identifier
  – administrative contact information.

Medication Incident Information
The Platform allows pharmacies to document medication incidents and near misses. Incident
records may include:
  – medication involved
  – description of the incident
  – stage of the dispensing process where the incident occurred
  – contributing factors
  – corrective actions taken
  – quality improvement notes

Limited Personal Health Information
Where necessary to document an incident, pharmacies may include limited patient-related information such as:
  – patient demographic information
  – prescription details
  – medication information relevant to the incident.

SafeScripts encourages users to minimize identifiable patient information whenever possible.

How We Use Information

Information collected through the Platform may be used to:
  – operate and maintain the SafeScripts platform
  – allow pharmacies to document medication incidents and near misses
  – support pharmacy quality improvement programs
  – generate safety insights and reporting tools for pharmacies
  – improve system performance and safety analytics.

Anonymous Reporting to the National Incident Data Repository

Medication incidents recorded within the SafeScripts platform may be reported anonymously to the National Incident Data Repository for Community Pharmacies, a national medication safety database maintained by the Institute for Safe Medication Practices Canada. The purpose of this reporting is to support national medication safety monitoring and help identify trends and prevent future incidents.

When incident information is shared with the National Incident Data Repository:
  – patient identifiers are removed
  – pharmacy identifiers are removed or anonymized
  – individual pharmacy staff members are not identified.

Only de-identified incident information is shared for safety monitoring and research purposes.

Data Ownership

All medication incident data submitted to the Platform remains the property of the submitting pharmacy. SafeScripts does not sell or commercially exploit pharmacy or patient data.

SafeScripts may generate aggregated and de-identified safety analytics derived from incident reports to improve medication safety insights.

Disclosure of Information

SafeScripts will not disclose personal information or personal health information except:
  – to the pharmacy that submitted the information
  – when required by law
  – when necessary to investigate security incidents
  – when authorized by the pharmacy.

De-identified incident information may be shared with medication safety programs, including the National Incident Data Repository, for the purpose of improving medication safety.

Data Security

SafeScripts maintains safeguards designed to protect personal information and personal health information. These safeguards include:
  – encryption of data in transit
  – encryption of stored data
  – secure cloud infrastructure
  – role-based access controls
  – audit logging and system monitoring.

While SafeScripts implements reasonable safeguards, no digital system can guarantee absolute security.

Data Retention

SafeScripts retains information only as long as necessary to:
  – provide services to pharmacies
  – support quality improvement programs
  – comply with legal obligations.

Pharmacies remain responsible for compliance with their own professional record retention requirements.

Privacy Breaches

SafeScripts maintains procedures for identifying and responding to security and privacy incidents.

If a breach involving personal health information occurs:
  – the affected pharmacy will be notified as soon as reasonably possible
  – SafeScripts will investigate and mitigate the incident
  – the pharmacy may be required to report the breach to the Information and Privacy Commissioner of Ontario and affected individuals where required by law.

Access and Correction

Individuals seeking access to or correction of personal health information should contact the pharmacy responsible for the information.

Because SafeScripts acts as a service provider to pharmacies, requests related to personal health information must generally be directed to the relevant pharmacy acting as the Health Information Custodian.

Third-Party Service Providers

SafeScripts may use trusted third-party infrastructure providers to host or process data.

These providers are required to implement safeguards that comply with applicable privacy laws.

Cookies and Website Analytics

The SafeScripts website may use cookies or similar technologies to improve website functionality and understand usage patterns.

Users may adjust browser settings to disable cookies if desired.

Changes to This Policy

SafeScripts may update this Privacy Policy periodically.

Updated versions will be posted on the SafeScripts website with a revised effective date.

Users may adjust browser settings to disable cookies if desired.

Contact Information

For questions regarding this Privacy Policy or SafeScripts privacy practices, please contact:

Privacy Officer
SafeScripts Inc.
Email: info@safescripts.ca