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June 26, 2012
Influential online Moms are not just about consumer goods. They have a strong and passionate voice when it comes to healthcare as well. So why isn't the Canadian pharmaceutical industry tapping into this powerful network to help raise awareness about various disease states and provide healthy tips? Perhaps some have and I am not aware. If this is the case, please let me know. By now, we all know that the industry is heavily regulated and anything that the bloggers write on behalf of an organization, whether on paper or in a blog, would be subject to the same guidelines that the pharma marketers must abide by. A little training, a set of guidelines and monitoring can greatly minimize this risk. As an example of what could be done, take a look at the Children’s Miracle Network Hospitals online fundraising campaign via “Miracle Moms”. Miracle Moms consists of a group of 10 passionate Moms with influential blogs; 7 are Canadian and 3 are American. They have joined forces to raise awareness for Children’s Miracle Network and Children’s Miracle Network Hospitals. These Moms are highlighting moments that take place at these children hospitals and are showcasing the needs of various families who are using these hospitals’ services. In addition, each blogger is running a fundraiser via their blog and social media profiles to help a local children’s network hospital in their area. Funds raised will be given to local hospitals for much needed services like Art Therapy, Child Life Rooms, and of course state of the art equipment. I am always impressed with the soft selling skills of online Moms, and have learned a lot from this group over the years. In speaking with Stephanie, the author of the popular Canadian Mom blog "How to survive life in the suburbs", here is the key learning that she took away from her participation in the Miracle Moms campaign:
"If you ask for help spreading the word about a heartfelt cause, you will receive. I continue to be amazed by the power of Moms who Blog and the way they will all jump in to lend a hand and socially amplify each others tweets, Facebook and Blog posts when it is a subject close to their hearts. Awareness of this cause has truly blossomed all thanks to the power of social media. In future programs we may consider using a twitter party at launch to truly get off to a dramatic start."Wouldn't a blogger outreach such as this one be a great way to humanize the pharma industry? Have you ever considered it as a PR tactic? Let us know your thoughts in the comments below. On a side note, congratulations to all the Mom bloggers who were involved as 'Miracle Moms' in this particular fundraising campaign. I personally appreciate all the hard work that you have put in for this very important cause, the health of our kids. Be sure to check out the blogs of these great ladies!
- My Organized Chaos
- How To Survive Life In The Suburbs
- Bored Mommy
- Things I Can't Say
- Tammy's Two Cents
- Nugglemama's Handful
- Loulou's Views
- Listen To Lena
- Busy Mommy
- CMNH Radio
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.
October 13, 2011
According to a new report posted by Statistics Canada ("Individual Internet use and E-Commerce, 2010"), 64% of Canadian internet users search for medical or health-related information vs, 58% who use social networking sites. In fact, only 33% of Canadian internet users play online games, and only 19% are contribute content or participating in discussion groups (e.g., blogging, message boards, posting images)
Unfortunately, the online activities are not broken down by demographics.
The report clearly states that one cannot compare data from previous reports to this most recent one because the methodology and questions for both are somewhat different. However, I cannot resist but post some of the stats from the 2009 report. Compare the 2010 and 2009 data at your own risk:
Health searches on the Internet (from the data collected 2009):
- Searching for health information online reported by 70% of home users
- 74% of women used the Internet to search for information about health or medical conditions, while 66% of men did so
The 2010 online activity for both health information search and social networking is quite high. Moreover, search engines are taking social media more and more into consideration when ranking webpages.
Isn't it time for all healthcare organizations and pharma companies to pay closer attention to their online activities in order to respond to the needs of Canadian consumers? Leave your comments on this topic below.
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.
July 7, 2011
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.
How Healthcare Companies Should Conduct Social Media Activities
Healthcare companies should conduct SMA within the scope of legally acceptable risk, which takes into account all of the relevant sources of exposure. I will share some thoughts about my approach to legal review of SMA. While I believe it to be true as of the time of posting, this information should not be taken as legal advice. You should always consult with a lawyer to discuss the implications of specific SMA to your healthcare company.
Regarding the legal review of ‘speaking' SMA, my practice is to perform a categorical analysis of the piece or project to determine which Regulations apply, then perform a qualitative analysis of the piece or project against the relevant Regulations to determine scope of the risk of exposure.
1) The first step in my categorical analysis is assessing whether the SMA is either informational or promotional in nature. A useful instrument in this analysis is Health Canada’s Distinction between Advertising & Other Activities.
2) Where products are involved, how are these categorized (prescription drugs, Class I medical device, natural health product, etc.) and which Regulations become relevant?
3) Next, I determine the intended audience of the SMA: healthcare professionals, patients, or the general public. This analysis will determine which Regulations apply, as each of these audiences is regulated differently. In the former two cases, are the strategy and tactics deployed necessary or sufficient to restrict access to the appropriate populations?
Only after I position the SMA within the above matrix do I begin to analyze its content. What restrictions do Regulations impose on acceptable condition-related or product-related representations? Because SMA is predominantly interactive, control of editorial content is directly correlated with risk management of exposure to non-compliance with Regulations; it is inversely correlated with communitarian and interactive notions which inform and influence SMA strategies and tactics. My practice is to educate brand managers and other marketing professionals about the scope of the risk, suggest strategies and tactics to mitigate or manage it, and leave the ultimate decision to the business people.
Turning now to the ‘listening’ or receiving of SMA messages from stakeholders, healthcare companies should be mindful of privacy law, personal health information law, and pharmacovigilence/adverse event reporting obligations. Again, my practice is to perform a categorical and qualitative analysis based on these five questions:
1) is there informed consent for the collection of all information being collected and all purposes for which it will be used?
2) Where will the information be stored, is this being disclosed to the stakeholder, and what are the regulatory implications for transmitting the information outside of the jurisdiction in which it was collected?
3) What safeguards are there to maintain the confidentiality of the information; are these necessary or sufficient?
5) Which legislative regime will apply to the collected information (privacy law, personal health information law, adverse event reporting law, other?)
Exercise extreme caution when the collected information about a specific product is publicly available.
The way in which healthcare companies engage stakeholders is changing from a didactic paradigm of information dissemination to an interlocutory paradigm which necessarily entails a relinquishing of control over information content. The reality is that healthcare companies need to use SMA in order to remain engaged and relevant to their stakeholders. Because SMA tactics and strategies are evolving faster than the Regulations, legal risk increases. Healthcare companies should consult closely with legal counsel who has expertise in the regulation of advertising and promotion of therapeutic products, at all stages of the development and execution of SMA, in order to effectively manage this necessary risk.