Guidance on Cloud Storage for Required LCB-Related Business Records
On June 21, 2023, the Washington State Liquor and Cannabis Board (LCB) withdrew CR-101 (Preproposal Statement of Inquiry) WSR 23-04-027 that considered rulemaking to allow cloud storage recordkeeping for all liquor, vapor, tobacco and cannabis licensees.
After further review, a determination was made that the rule filing was not necessary, and that formal guidance is more appropriate.
All licensees may use digital/electronic formats (i.e., cloud storage) to maintain records that are required to be kept on the licensed premises per Title 314 WAC; if the following requirements are met:
- Cloud storage recordkeeping must comply with all the applicable statutes and regulations related to retaining, maintaining, and preserving records on the licensed premises.
- Records must be easily accessible and immediately available at the request of the LCB.
- Inability to access or produce records at the time of request due to technical issues is not considered to be a mitigating circumstance. Technical issues include, but are not limited to: power outages, disruptions in internet service, or changes made to the cloud storage or point of sales system.
Best Practices:
- Keep duplicate records and frequently back up an external hard drive to prevent loss of, and ensure access to, required records.
- Use a consistent naming convention to organize records.
- Ensure at least one employee who has access to records is always on the licensed premises.
To see the information on the WSLCB site click here. If you need additional guidance related to this issue, contact Gleam Law and we can help.