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PAAB Offers Guidance on Regulatory Social Media Thought Process
Eye for Pharma organized the 1st eMarketing Canada conference, which was held in Toronto, on November 1-2 2010.
Patrick Massad (Chief Review Officer at the PAAB, Pharmaceutical Advertising Advisory Board) presented an algorithm to facilitate the regulatory thought process when planning a social media promotional activity. Here is the suggested algorithm:
1) Is this advertising?
2) Who is the intended audience?
3) What restrictions should I consider for this audience with respect to disease and product schedules?
4) What mechanism will I use to limit access to that audience?
5) What is the sponsor’s tolerance for uncertainty & risk?
6) How will I align the site with this tolerance level?
7) What are the regulatory consequences of adding and/or linking other tools/content to my site?
Here are some highlights of Patrick’s presentation with regards to the very 1st step to detemine if tactic in mind is advertising or not:
Health Canada’s definition of advertising is as follows: “any representation by any means whatever for the purpose of promoting directly or indirectly the sale or disposal of any food, drug, cosmetic or device” (as per section 2 of Food Drugs Act).
If this does not help to answer the question about whether the promotion is advertising or not, you can then refer to Health Canada’s policy document “The Distinction Between Advertising and Other Activities”, which lists the following 7 questions:
•What is the context in which the message is disseminated?
•Who are the primary and secondary audiences?
•Who delivers the message (the provider)?
•Who sponsors the message and how?
•What influence does the drug manufacturer have on the message content?
•What is the content of the message?
•With what frequency is the message delivered?
By answering these questions, the intent of the promotion becomes clearer as to whether the tactic is advertising or informational.
The intented audience and type of drug will determine which regulatory body needs to be consulted. See this article here if you need assistance to determine which Canadian regulatory body to consult for your promotional campaign.
For more information about PAAB guidelines regarding social media, see Highlights from “Social Media Marketing in Pharma: What Works in Canada”
What do you think of this algorithm? Would you add, delete or change any of the suggested steps? Please leave a comment below.
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