Alert: 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.

For questions, please e

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