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August 22, 2012
Ray Chepsiuk, the Commissionner for the PAAB (Pharmaceutical Advertising Advisory Board), recently made a comment about whether PAAB "kills creativity". You can listen to the podcast here (it is about 5 minutes in length, and his comments about 'creativity' can be heard near the end of the podcast). A written transcript will be made available very shortly. Here are the key points that Ray made:
- Creativity is delivering results within specified criteria.
- If you understand the rules, you can do great pharma marketing.
- It’s an excuse and a cop-out when people say that the regulations keep them from great pharma marketing.
March 1, 2012
Less than 2 years ago, I got very excited when I saw a Canadian pharma ad on my FaceBook profile. It was the first Canadian pharma ad that I had personally ever seen on FaceBook. You can read my post about it here. We sure have come a long way since then. Throughout 2011 and so far in 2012, I have spotted several ads on my FaceBook profile, by Canadian pharmaceutical companies. In fact, Pfizer Canada might be the first Canadian pharma company to advertise a Schedule F prescription drug name on FaceBook. In Canada, pharmaceutical companies must follow very restrictive Rx-DTC (direct-to-consumer) guidelines. The only things that can be mentioned in the public regarding Schedule F Rx products are product name, price and quantity. The ad below complies with the regulations. GlaxoSmithKline Canada promoted their vaccine Cervarix via FaceBook ads back in Q4 2011. Although the product name and disease state appear in the ad, it complies with Health Canada's Rx-DTC regulations because Cervarix is a schedule D drug, and it is not promoting a schedule A disease. Now Midol might not be a prescription drug, but it belongs to Bayer which is a pharmaceutical company, so I think that they deserve kudos for entering the social media advertisement arena. The Midol FaceBook ads were very consumer-savvy, offering a prize and driving traffic to their site by offering entertainment in the form of punishment on the man in the ad - it doesn't sound very nice, but I saw the site and I did not find it offensive at all. It was all in the name of fun. The rest of the FaceBook ads by Canadian pharma companies that I saw on my profile were all to help raise awareness of certain disease states. As long as no brand name is mentioned, this is a completely acceptable form of promotion according to Health Canada. There might have been ads targeted to men, or younger / older audience, or other demographic that did not fit my profile, so this is by no means a complete inventory of Canadian pharma ads on FaceBook. If you have seen other FaceBook ads by Canadian pharma, let us know in the comments section. If you happen to have a picture, e-mail it to me and I will gladly add it to the post and give you credit for having found it.
February 13, 2012
This is a guest post by Timothy Dunn, Legal Advisor to Healthcare Companies Doing Business in Canada. You can find Timothy on Twitter here, and here is his website. If you have any questions, or would like to discuss a particular matter, you can contact Timothy at email@example.com or (450) 951-1335.
Patent law is intended to reward innovation with exclusive commercialization rights. Competition law is intended to do the exact opposite: foster market competition. Managers of healthcare companies doing business in Canada need to know the answer to a very important question: where do the limits of exclusivity granted by a patent end and the limitations of the Competition Act begin? Pharmaceutical patents enjoy three forms of protection under Canadian law:
- the general patent protection under the Patent Act,
- the supplementary protection under the Patented Medicines (Notice of Compliance Regulations), and
- Data Protection under the Food &Drug Regulations.
- patent infringement litigation settlements,
- restrictive covenants between firms operating in the same product market,
- licensing transactions, and
- acquisition and prosecution of patent rights,
August 15, 2011
One of the features that Google Plus offers is the ability to limit and maintain a message within 'circles', which are pre-selected members by the administrator of the Google Plus account. I was very excited about this the day that Google Plus launched, but I had not played with the site long enough to really be sure that it would be possible to contain a message within the circle. Here is a link to my original blog post on the topic. Since that day, I can now confirm that this could indeed work for the pharma industry, even in Canada (and other countries with restrictive regulations). Here are the steps:
- Pharma company sets up a business page (once these are allowed by Google Plus)
- Members who wish to receive messages from the pharmaceutical company must prove somehow that they have a prescription for the product. They can do this by providing the DIN or other information that is acceptable within regulations.
- Only those members with proof of prescription are then added to a pre-defined circle. Be careful not to have too many circles, as it could be easy for an administrator to make an error and send the message to the incorrect circle (and we all know this would result in a regulatory 'no-no')
- Pharma company writes post and clicks on 'share'. Make sure only the appropriate circle is included, and avoid at all cost using the 'public' share button.
- Once the post has been shared, click on the arrow button on the top right corner of the post. This will bring down a drop-menu which allows you to select 'disable comments' and / or 'disable reshare'.
In Canada, pharmaceutical companies must follow very restrictive Rx-DTC (direct-to-consumer) guidelines. The only things that can be mentioned in the public regarding Schedule F Rx products are product name, price and quantity. Not very exciting for consumers, patients, healthcare professionals, or any other stakeholder. However, Canadian pharmaceutical companies are allowed to provide product information to patients who have received a prescription from a healthcare professional for their product. This is referred to as direct-to-patient (DTP) marketing. Unfortunately, it is nearly impossible to develop a gated social site which only includes members who have a prescription for a particular drug, on a mainstream social media site. That is until Google Plus showed up. Of course, there are companies that specialize in customized gated sites, but in this blog post, I am referring to the popular social sites which are already frequented by the general public.
Here is what Ray Chepesiuk, Commissioner (CEO) of PAAB (Pharmaceutical Advertising Advisory Board - Canada), had to say about Google Plus and the pharma industry:
"This is a good example of what I was talking about years ago. The regulations still apply, it is the media that does not fit eg Facebook and Twitter for Canadian Pharma. In Google+ we have an example where the media has changed in a direction that is more amenable to Canadian Pharma communicating through social media to patients and doctors about brand information that is directly related to the product monograph. It will be interesting to see if doctors and patients want to communicate directly within a pharma sponsored site. It does make the creativity box bigger. It will also be useful for internal communications and also with KOLs and other external suppliers. Hopefully pharma will get to understand the utility of these media tools and get good advice on how to adapt them within the regulatory framework. The PAAB can help you do that through the preclearance review program."
Now we just have to wait for Google Plus to allow businesses to set up pages (impatient finger tapping by me and many others).
In the meantime, if you have not tried Google Plus yet, I urge you to do so. Once Google Plus does announce that businesses are allowed on its network, you don't want to be scrambling to start figuring out the network. If it's an invitation that you are waiting for, here is one from me. Just click this Google Plus invitation link and enjoy!
This is a particularly important topic today because FaceBook is no longer supporting pharmaceutical companies who want to disable comments from their FaceBook page walls. You can read more about it here. Some pharmaceutical companies are responding by simply removing their FaceBook pages. You can keep track of which pharmaceutical FaceBook pages are staying up, and which are being removed in the Dose of Digital blog.
Do you think pharma companies who have removed their FaceBook page, or who would like to use a similar type of networking format, would consider Google Plus as an option (of course, only once Google Plus allows business profiles on its network)? Please let me know if the comments below.
August 15, 2011
If you were in Novartis` shoes, what would you have done differently?
On August 10th, 2011, Novartis publicly called it quits for its "Maybe Someday" social media campaign. They announced the demise of the campaign on Twitter. Other than the Twitter post, one would probably not have even noticed that the campaign got pulled:
A few stats and pics of the campaign at closure:
Their Twitter stats as of August 14 2011 consisted of 94 tweets, following 392, followed by 125 and listed 5 times. There weren`t many tweets for this account, but I want to give acknowledgement to Novartis for taking the time to thank new followers and those who wrote a `hope` on their main site. In fact, almost all of their tweets mentioned somebody on Twitter.
The Maybe Someday FaceBook page could not be found as of August 14 2011.
The MaybeSomeday.ca site was still up as of August 14th, and it showed a total of 2,811 hopes (despite an objective of 25,000 hopes). When I wrote about the campaign back in April, it had 1,175 hopes.
The Maybe Someday site is still promoted on the main Novartis Canada site, but I`m sure that this will be rectified very quickly.
Reflection on the Maybe Someday campaign:
First of all, the only reason why I even found out that something was up with the Maybe Someday campaign was when I was going through my list of Canadian healthcare FaceBook pages to see if any of them had been shut down as a result of FaceBook no longer supporting pharmaceutical companies` request to disallow comments on their wall. The Maybe Someday page didn`t show up, so I dug further and that`s how I got to their Twitter statement.
Despite the timing with FaceBook`s actions with pharmaceutical pages, I think the closure of the site probably had more to do with the low number of hopes that were generated within the 8-month period of the campaign. This is my gut feel. Nobody from Novartis Canada has confirmed this.
Why so few hopes versus the objective? Was it the lack of advertising? Did Novartis have a `build it and they will come` mentality when it came to social media? The limited `human touch` involved in the campaign, which is typically expected in social media (but of course, is limited when one wants to remain within regulatory guidelines). Was it that people just weren`t excited by the amount to be provided as a charitable donation ($25,000)? Did Novartis Canada just not give the campaign enough time? Social media campaigns are usually expected to run for years. It is probably a combination of all of these.
Whatever the reason, I hope that Novartis Canada has taken some key learnings from this short-lived campaign, and will be willing to apply these in a future tactic involving social media. Eric Shenfield, eMarketing Manager at Novartis Canada, will be speaking at the upcoming eMarketing Canada (Eye for Pharma) in November in Toronto. Hopefully his presentation will allow him to share some of Novartis` key learnings with the rest of us, so that we can all learn.