The letter you received is a follow on from the guidance letter sent to all pharmacy superintendents / owners in April. This guidance and inspection regime is more about clamping down on lax pharmacies providing their own form based online doctor consultation service, private prescription fulfillment for other form based online consultation services, pharmacies fulfilling scripts originated abroad / sent abroad .. lax pharmacist prescribers with online services etc etc.

With the regards to the risk assessment here's some advice as to how that pertains to your website provided by The Pharmacy Centre.

You should not have either your own or any third party provided online doctor consultation services on your site that use a form based approach and where the patient journey is choose a condition, choose a treatment, fill in a form.

Pharmacies on our network who did request us to add links, banners etc to online consulation services using a form based service to their sites were mainly using PharmaDoctor, Fast Doctor and Anytime Medical. The providers of these services have shut them down. If you have menu links, homepage icons, banners, blog posts etc linking to online consultation services that don't meet the GPhC guidance, be sure to get in touch with us and request that they are removed.

If you don't have a live page on the MHRA register of online sellers of  medicines and don't have the Common EU logo linking to your MHRA register page displayed in the footer of your website, no gsl /pmed / poms are available for sale on your website. 

If you do have a live page on the MHRA register of online sellers of  medicines and do have the Common EU logo linking to your MHRA register page displayed in the footer of your website AND if gsl / pmeds were enabled, your are not supplying or fulfilling those orders. The customer is transacting with HI Weldrick Ltd (weldricks.co.uk) who are of course inspected by the GPhC. This is made clear to the customer via the common eu logo for shopping in the footer, when they register, in the Ts and Cs and before they actually pay. To buy something, a website user must register first. Weldricks have produced their own comprehensive risk assessment which includes reference to sales fufilled via the white label online store provided by The Pharmacy Centre.

The only other service you provide online is a facility to request nhs repeat prescriptions. The patient is registered with an nhs surgery, has chosen a pharmacy owned by you as his/her nominated pharmacy and you are only fulfilling script requests that are issued and approved by the patients' GP and available on the spine for you to download.