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April 8, 2013
There is more to FaceBook advertising than just the typical ads that you see on your profile's homepage, or sponsored stories. In March 2013, targeted Canadians got to see a healthcare ad right on FaceBook's front homepage. I hope we will see more of these.
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.
April 12, 2011
Here's an interesting Canadian pharma case study where the social media campaign seems to be very well designed and executed, but reaching the intended audience and getting them to take action is proving to be a rather slow process. The details of the campaign are below. Share your thoughts with us on the Maybe Someday campaign in the comments section. In January 2011, Novartis Canada kicked off a social media campaign, "Maybe Someday", designed to raise up to $25,000 for the Canadian MS Society. This is a purely Canadian initiative. Considering their drug Gilenya® (fingolimod) capsules, the first oral disease-modifying therapy developed for relapsing-remitting MS, was approved by Health Canada on March 9th 2011, the Maybe Someday campaign was most likely a pre- and early launch tactic to raise awareness of Novartis as a player in the MS industry, and to develop a relationship with key MS stakeholders. As such, Novartis and Tank, the agency who developed the site, designed the Maybe Someday campaign so that it would be more than just a fundraiser. Despite following restrictive regulatory guidelines, the campaign manages to provide an emotional and memorable experience to the multiple sclerosis (MS) patients, friends, relatives and caregivers that participate. These stakeholders get to write a hope that they have regarding MS, either for themselves or a loved one. What can be more emotional than somebody's hopes and dreams. Just read some of the hopes that were written on the main site so far, and you will see that many people poured their heart and soul into their 'hope' statement. There is no real motivation for repeat visits to the site, but I don't think that was part of the objective for the campaign in the first place. The main component of the campaign is the MaybeSomeday.ca site, where a 2 minute and 15 second video explains the concept of the site and encourages people to write their hope. The main site clearly states that Novartis is behind this initiative. I am assuming that regulatory issues concerning the restrictive Schedule F Rx-DTC advertising in Canada have been taken into consideration, thus restricting all mentions of drugs:
"Please note that we can't post messages about medications and treatments - only inspirational thoughts and wishes."You can scroll through the hopes that people wrote on the left side of the screen, and the bottom left keeps a tally of the English and French hopes which have been written thus far. As mentioned earlier, some of them are very touching. The user's experience would be enhanced if they could comment on the hope of others. But according to the “Social Media Marketing in Pharma: What Works in Canada” conference, a pharmaceutical company is responsible for all content within their site, regardless of who posted it. If people were to share information with each other about their treatments or disease on the Maybe Someday site, Novartis Canada would hold full liability for this content. Novartis could allow it, but they would have to monitor and edit in order to ensure that the comments stay within the guidelines. They could however add a 'like' button or something similar to allow people to at least show support to the author of the hope. Other case studies of Canadian pharma companies who are involved in social media but do not accept comments can be found here, here, and here. I added my hope on the MaybeSomeday.ca website. You can see it just below this paragraph. After your hope has been submitted, you are encouraged to help spread the word about the site via Twitter, FaceBook and e-mail. An automatic message comes up for Twitter, which includes the hashtags #maybesomeday and #MS. Upon scanning the #maybesomeday hashtag: it is being used by many people who are writing a wish on Twitter, very few of which were regarding the MaybeSomeday.ca site (ie. looking for the right girl or guy, wanting to attend a fun event, etc...). FaceBook page as well as a Twitter account. These are promoted from the main site. There is a YouTube channel as well with the Maybe Someday video, but there is no activity at all there and Novartis is not pointing anybody to its direction either. Interestingly, none of these sites mention the name "Novartis", except that the FaceBook page 'likes' the Novartis FaceBook page. However, they all link back to the MaybeSomeday.ca site, which does mention Novartis twice. The FaceBook, Twitter and YouTube profiles were all set up by Tank. The posts are all kind of similar, in that they are promoting the MaybeSomeday.ca site, and are encouraging community members to write a 'hope'. There is little engagement on the FaceBook page because members are only able to 'like' and share a statement. It is noted on the FaceBook information tab that "This page can't save your comments". I decided to test this out. I was able to write a comment, and it was visible for a short little while, but it was then quickly removed. As for the Twitter account, the messages are also very focused on sharing info and the link to the MaybeSomeday.ca site. However, it seems as though Novartis is taking the time to thank the people who are posting information about their site on Twitter. I got a thank you note very quickly after I promoted their site, and I saw a few others on their post timeline. You may have noticed that there is a very small following on both the FaceBook and Twitter profiles. As of April 8 2011 morning, there were almost 1,200 hopes. Novartis has an objective of 25,000 hopes in order to raise $25,000. Considering the site has been up for about 3 months already, that averages out to about 10 hopes per day. At this rate, it will take another 6 1/2 years for Novartis to achieve their objective, which is probably longer than Novartis plans to keep the campaign alive (this is my personal guess, nobody from Novartis told me this). My immediate thought was that perhaps there was a lack of advertising of the campaign. It seems as though there has been FaceBook advertising. People who visit the site and write a hope are then encouraged to help spread the message via their social networks. Traditional promotion of the FaceBook and Twitter sites has been through the MaybeSomeday.ca main site and on the home page of the Novartis Canada site. Based on this info, I do believe that the MaybeSomeday.ca campaign is getting fewer 'hopes' and minimal community members because there is a lack in advertising of the program. Personally, I find the program was designed and implemented very effectively, but low awareness is an issue.
Could the MS Society of Canada help to spread the word about the campaign? I spoke with Rob Petrollini, Manager Web and New Media at the MS Society head office and asked if the MS Society had posted anything about the MaybeSomeday.ca campaign on their social networks. Their Facebook and Twitter profiles have a large number of community members (FaceBook has over 6,400 members, and Twitter has over 2,500 followers as of April 8th 2011). Surely a quick post about the MaybeSomeday.ca fundraising activity would drive their members to help raise the donation and follow the campaign on either FaceBook or Twitter. But unfortunately the MS Society has a policy that prohibits them from promoting any pharmaceutical company program, so they have not posted anything related to the Maybe Someday campaign:"The MS Society's total revenue from pharmaceutical companiesis less than 2% of the amount of money the organization receives annually. Any pharmaceutical funding received by the MS Society of Canada is subject to the MS Society's strict policies that prevent any control or influence by the donor on our decision-making. This is consistent with the ethical principles of Canada's research-based pharmaceutical companies which require that they assure the independence and integrity of stakeholders, in terms of their operations, policies and activities." This is a shame because the Maybe Someday campaign was developed by following the restrictive regulatory guidelines regarding Canadian Rx-DTC advertising. I find it hard to believe that the MS Society community members would have a more negative perception of the society if they were made aware of the Maybe Someday campaign. If a consumer company would sponsor a similar initiative, would the medical organization promote it? I'm not sure what the answer is to that question, but this might be a good topic for a future post. So what are your thoughts on the Maybe Someday campaign? Please share in the comments section. Disclosure: I have no ties with the Maybe Someday campaign, and Novartis is not a client of mine. I just find their site interesting, and I hope that Novartis reaches its goal so that the MS Society of Canada can get the full $25,000.
February 15, 2011
A few days ago, I visited the websites of all the Canadian drugstore chains that were listed in Wikipedia. I looked for their Twitter, FaceBook, YouTube and any other social media and mobile app logos. I only looked at channels and profiles set up by the corporate head offices of Canadian pharmacy chains. Online drugstores which do not dispense Rx prescription drugs were omitted from the analysis. During my search, I saw many independent pharmacies and even individual chain stores who were active on various social networks, but I did not include these as part of this post. Here are some statistics as of February 14 2011, based on an overview of the drugstore chains’ websites . It is possible that some drugstores have social profiles that are not listed on their corporate site homepage, therefore are not noted in this report. If you know of any that should be added to the list, just let me know in the comments section:
- 7 drugstore chains have at least 1 social media component listed
- 16 drugstore chains have no social media component
- Neither of the 2 online drugstore chains have a social media component
- 5 drugstore chains have a FaceBook page
- 4 drugstore chains have a Twitter account (5 if you include PharmaPrix)
- 1 drugstore chain has a YouTube channel
- 2 drugstore chains have a blog
- 2 drugstore chains have an app
- Shoppers Drug Mart FaceBook page has a strong lead in number of ‘likes’ and a moderate lead in number of followers on Twitter.
- London Drugs is the most ‘listed’ Canadian drugstore chain on Twitter
- London Drugs has the highest Klout rating on Twitter (The Klout Score is the measurement of your overall online influence. The scores range from 1 to 100 with higher scores representing a wider and stronger sphere of influence. The Klout score is highly correlated to clicks, comments and retweets.)
- Pharmaprix was the 1st to join Twitter, but their account is inactive … so in my opinion, this does not count. Therefore, the runner-up, London Drugs, was the 1st Canadian drugstore chain to join Twitter and to be active on this network.
|Association||FaceBook # of Likes*||Twitter Stats*||YouTube Stats*||Blog||App|
|Canadian Pharmacists Association||Yes 221||Yes 99 followers Listed 8 times 24 updates Klout: N/A Joined Mar 11 2010 Last post Aug 30 2010|
|Canada Drugs||Yes 3,629 (a huge jump from just 2 weeks ago, where they had 2,813 community members)||Yes 324 followers Listed 2 times 37 updates Klout: 26 Joined Aug 19 2009||Yes|
|Jean Coutu||Yes Prescription refill for entire family|
|London Drugs||Yes 1,751||Yes 2,535 followers Listed 197 times 6690 updates Klout: 55 Joined Jan 2 2009||Yes 37 subscribers 72,035 upload views Joined Jan 2 2009||Yes|
|Pharmaprix (the Quebec equivalent of Shoppers Drug Mart)||Yes, sort of 25 followers Listed 1 time No updates Joined Oct 30 2008 The site is completely inactive. It lists the actual Pharmaprix.ca website as its URL, but other than that, it seems completely unofficial.|
|Shoppers Drug Mart||Yes 18,326||Yes 3,282 followers Listed 171 times 756 updates Klout: 42 Joined Apr 25 2009||Yes Weekly flyers, points tool, prescription refill, promotions and offers, store locator|
|Uniprix||Yes 2,184||Yes 577 followers Listed 32 times 331 updates Klout: 29 Joined Oct 20 2009|
- Both organizations are engaged with their followers and are responding to posts by others, but London Drugs is doing so at an incredible rate on Twitter. In fact, London Drugs has posted on Twitter almost 9x as often as Shoppers Drug Mart.
- But who cares if London Drugs tweet a lot. Volume does not mean quality. But in this case, London Drugs have proven the level of quality of their engagement on Twitter with their higher Klout rating. This needs to be taken with a grain of salt though, as this figure can fluctuate quickly depending on engagement activity within a certain period of time.
- London Drugs has a successful YouTube channel. This is not only strategically clever from an 'online search' perspective, but it is also a great way to showcase your products.
- The #1 reason why I am naming London Drugs as the most social Canadian Pharmacy chain vs. Shoppers Drug Mart, is because London Drugs serves the Western portion of Canada only, whereas Shoppers Drug Mart serves the entire nation. So what? If you look at the amount of social media effort put in on a 'per potential client' basis, London Drugs is by far the leader. However, one might argue that their ROI may be weakened as a result.
December 13, 2010
If you suffer from pain, are you inclined to see laughter as the best medicine? McNeil Consumer Healthcare (a division of J&J) is counting on it. McNeil Consumer Healthcare is the Canadian distributor of Motrin®, pain relief over-the-counter medication. On Thursday December 2nd 2010, a new Motrin® Canada FaceBook page was launched. At the moment, the main promoted feature of the page is an app called "The Wicked Pain-Poker". I was fascinated by this creative use of social media by a Canadian healthcare organization, so I joined the page 2 days after its launch, and I was the 170th person to 'like' the page. As of Sunday December 12th 2010, there were 1,046 members of this new community. The Motrin® Canada page is being promoted, with a focus on the Wicked Pain-Poker app. It appears to be heavily promoted on FaceBook. So far, I have seen three variations of the "Motrin® Wicked Pain-Poker" ad on FaceBook, and an ad for the Motrin® Canada page seems to appear on my FaceBook profile every time I log on (and I log on several times per day). I also saw an interactive ad on Yahoo Canada. The ads all caught my attention very quickly - they are colourful, with an interesting voodoo doll, and the copy peaks your curiosity. The interactive Yahoo ad may be a bit violent for some people's taste, but these people are probably not the target market for the Wicked Pain-Poker app on the Motrin® Canada page (and they would definitely not like using the app itself). [caption id="attachment_1588" align="aligncenter" width="468" caption="FaceBook ads for Motrin Canada FaceBook page - December 2010"][/caption] [caption id="attachment_1589" align="aligncenter" width="468" caption="Interactive Yahoo Canada ad for Motrin Canada FaceBook page - December 2010"][/caption] There was no promotion of the FaceBook page on the Canadian Motrin® site itself. The site looks a little outdated (customer comments all date from 2003 and the special offer that is promoted is no longer available), so promoting their social media activities may not be a priority for the organization at this time. Once you click on one of the ads, you are brought to the Motrin® Canada FaceBook page, on the Wicked Pain-Poker app tab. Then you select which friend you want to poke, crop their photo in the 'face' of the voodoo doll, identify whether it is a male or female, ... and then you get to poke the doll wherever you want. SPOILER ALERT - do not continue to read if you want to find out by yourself what happens once you poke the doll, but please come back to tell us what you think though. From what I could see, there are 3 variations of outcomes depending on where you poke the doll: A) if you poke in the head, a piano drops on the doll, B) if you poke in the torso, a shark eats the doll's arm (same as in the Yahoo Canada ad), and C) if you poke in the legs, a pinata donkey charges at the doll and makes the doll fall. Ouch ouch ouch !!! Once the poke outcome is completed, you have the choice of sending the pain poke to your friend or not. So if you had a lot of fun inflicting pain on one of your FaceBook friends and then get a guilty conscious that maybe this person might not appreciate the joke, the person will not know unless you send them the message. Maybe I am being naive, but my bet is that most people will have fun with the app to see the different outcomes, but they won't send it to their friends. Would you send it? I am not sure that I would. But if you do decide to let your friend know that you have poked them, you can write a personalized note. You will notice that at the bottom right corner, there is an offer for $5 off Motrin®. Just that might be enough to get some people interested in checking out the Wicked Pain-Poker app. Community rules and monitoring: Now although this is meant for fun, McNeil Consumer Healthcare takes the management and monitoring of the Motrin® Canada FaceBook page very seriously. Members of the community may post statements and comments on the Wall, and they can also 'Like' posts, but there are rules that members must to follow. See the rules below. You will notice that members are asked not to post adverse reactions /events while using a particular product. The organization is very clear that if adverse reactions / events are posted on the page that they will be disclosed to the appropriate authorities, including member's name : The posts made by members of the community have been minimal so far, but in fairness, the site is only 10 days old at the time of writing this article. There have been several posts that fall within the "I love this page" category, and 1 post from an offended pain sufferer. As the number of posts grow, we will see how the community members truly feel about the page. Motrin® Canada has so far only written 2 posts themselves, and have not commented on any of the members' posts yet. It is still early to see what type of engagement will fall out of the Motrin® Canada page, but I certainly look forward to watching it unfold. My guess is that the target audience for the Wicked Pain-Poker is somebody who experiences pain on occasion, or maybe not at all (at least not yet, with the hopes that if they ever do, that Motrin® will be the brand that comes to mind first). Chonic pain sufferers might be more apt to find the application too offensive, and they could feel ridiculed. Although this has not been confirmed, my assumption is that the organization is prepared to respond appropriately if the Wicket Pain-Poker app gets too much negative feedback from pain sufferers based on J&J's previous (and very public) experience with the Motrin® Moms situation. Other Motrin® Moms case study resourcer here. What is the strategy of the Motrin® Canada FaceBook page? According to David Akermanis, Producer/DJ. Account Manager, Health at Edelman, the strategy is to reinforce the brand’s position as the pain reliever that ‘targets your pain’. The Motrin® Wicked Pain-Poker Application is a fun and light-hearted way to bring that positioning to life. Is this the first time that Motrin has been involved in light hearted jabs at pain? No way! You might recall the Motrin® Wickedest Wipeouts Contest which was held earlier this year. According to David Akermanis, the Wipeouts Canada contest really emphasized the passion with which Canadians are engaging online. As such, McNeil Consumer Healthcare wanted to take that a step further by starting the Motrin® Canada Facebook Page. David also states that although the Motrin® Canada Facebook Page is the only Canadian Motrin social media property at this point, there are additional opportunities that the Motrin® team is looking at for 2011. Agencies involved: TAXI developed the Motrin® Canada Facebook Page and the Motrin® Wicked Pain-Poker Application, Edelman is responsible for community management/measurement and J3 Canada is responsible for the online media buy. Many thanks to David Akermanis, Producer/DJ. Account Manager, Health at Edelman, and Rachel Segal, Consumer Marketing Account Director at Edelman for their help in answering some of my questions about this case study. ------------------------------------------------------------------------------------------ Despite the fact that the Motrin® Canada Wicked Pain-Poker app is meant for fun, pain is a very serious issue that affects many Canadians. The Canadian Pain Coalition reports that 17% to 31% of the general community report chronic pain. Hopefully it is true that laughter is the best medicine and that some pain sufferers can relieve a bit of their pain for at least a moment or so by being a member of the Motrin® Canada FaceBook page. I encourage you to join the Motrin® Canada FaceBook page and test out the Wicked Pain-Poker app. Do you want to test the Wicket Pain-Poker app without risk of insulting any of your FaceBook friends? Then feel free to use me as your guinea pig - I won't take offense. You can find me on FaceBook here . Seriously - go ahead! What do you think of the Motrin ® Canada FaceBook page and the Wicked Pain-Poker app? Is McNeil Consumer Healthcare targeting the right audience with this tactic to drive their business? Stay in touch, Natalie Connect with me on the following networks: FaceBook, Twitter, LinkedIn