Subsection 4: Closure of the pharmaceutical record

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Article R1111-20-9

French Public Health CodeIn force

Updated 6 Nov 2023

The pharmaceutical record is closed by the Conseil national de l'ordre des pharmaciens when the holder so requests under the conditions set out in article R. 1111-20-6.

When the Conseil national de l'ordre des pharmaciens observes a situation or an event revealing a serious technical malfunction or fraudulent use of the pharmaceutical record which it cannot correct, or when it observes that a record which has been open for more than three years does not contain any of the data provided for in c of I of article R. 1111-20-2, it may automatically suspend access to the record in the interests of the holder concerned. It shall inform the holder in accordance with the procedures set out in I of article R. 1111-20-1 and, in the absence of any objection from the holder within six weeks of this information being provided, shall automatically close the pharmaceutical record.

When the beneficiary of health insurance is an unemancipated minor or an adult subject to a legal protection measure with representation relating to the person, the information provided for in the previous paragraph is sent to the legal representative or the person responsible for exercising the measure, who may object to the file being closed.

Closure of the file results in the deletion of the data and traces contained therein.

After closure of the pharmaceutical file, the Conseil national de l'ordre des pharmaciens retains, for a period of ten years from notification that the closure has been taken into account, the data relating to the identity of the beneficiary, his contact details, where applicable those relating to his legal representative or the person responsible for implementing a legal protection measure, as well as the trace of the closure. This record, which is kept in conditions that protect the confidentiality of the data, is intended to ensure compliance with the decision to close the file.

Beneficiaries of health insurance whose pharmaceutical record has been closed may at any time request the creation of a new pharmaceutical record from the Conseil national de l'ordre des pharmaciens.

Mariela Petrova

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Working with a corporate lawyer in France — Q&A

Any time a strategic decision changes how the company is owned, governed or contractually bound — incorporation, fundraising, M&A, restructuring, shareholder agreements, or major commercial contracts. Earlier engagement always costs less than later remediation.

A notary (notaire) is a public officer who authenticates specific deeds (mainly real-estate transfers and certain family-law acts). A corporate lawyer (avocat) advises on strategy, negotiates and drafts company documents, and represents you in disputes. The two roles complement rather than overlap.

Yes — most of our clients are foreign suppliers, investors or holding entities. We bridge the gap between French law and your home jurisdiction's expectations and deliver everything bilingually.

The SAS (Société par Actions Simplifiée) is the default choice for most international structures: flexible governance, single shareholder allowed, no minimum capital, and works cleanly with foreign holding entities. We assess SARL, SA, SCI on the merits when the situation calls for it.

Yes — communications with a French avocat are protected by the secret professionnel (Article 66-5 of the Law of 31 December 1971). This protection is broader than the common-law attorney-client privilege and applies to written and oral exchanges.

We work on fixed fees for clearly scoped engagements (incorporation, contract drafting, audits) and on monthly retainers for ongoing advisory. Hourly billing is the exception, not the default. You always know the cost before work starts.

Typical timeline is 2–3 weeks from KYC kick-off to RCS registration, assuming standard documentation. Holding-company structures, foreign-shareholder identification or in-kind contributions can extend this — we flag the gating items at the first meeting.

Absolutely. We routinely coordinate with your in-house counsel, expert-comptable or notaire — pragmatic collaboration is the norm, not the exception. We send them everything they need to do their part without duplicating work.

Mariela Petrova

Mariela Petrova

Avocate au Barreau de Paris

Toque #C2396

15+ Years In Corporate Practice

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Communications protected by professional secrecy — secret professionnel de l'avocat, Article 66-5 of the Law of 31 December 1971.

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