Facebook Tells Pharma Brands They Must Allow Comments
"Previously, pharmaceutical brands could submit a request through their Facebook Sales Representative to disable commenting on their Facebook Page," the email read."We think these policy changes support consistency for the Facebook Pages product and encourage an authentic dialogue between people and businesses on Facebook," it continued. "However, we also understand that these changes may lead you to re-evaluate your strategy and presence on Facebook. We are committed to helping you during this transition." This applies to new pages immediately: brands with pre-existing pages will be required to allow comments after August 15 2011.
Many will welcome this, and indeed, it presents an opportunity for pharma to engage in dialogue with their consumers: to deal with issues, improve product, form relationships. However, it is not without problems, in addition to the normal concerns attendant with UGC (defamation, inappropriacy, copyright, libel, etc), there is the as yet unresolved problem of what to do about the reporting of adverse effects.
In the US, pharma marketers are required to report adverse effects of their drugs, so if someone posts a comment about an adverse effect on a Facebook page, the company is responsible to report that to the Food and Drug Administration. Also, when they become aware of online conversations including incorrect or off-label information about their drugs and products, they need to notify the FDA. The FDA has yet to determine official guidelines for pharma brands operating in digital media, so pharma marketers tend to be extremely cautious in their decision making about how to use things like online advertising and Facebook pages.
On the other side of the pond, a similar situation exits. Unlike in the US, the European Directive 2001/83 (Community Code) forbids public advertising of “prescription-only medicines”. On the other hand, EU offers little specific guidance on social media (apart from some EFPIA -guidelines on websites, and the PMCPA’s (UK) “Brief guideline on blogs”), and waits for the US approach; however, FDA rules on pharma, internet and social media, which draft was due at the end of 2010, still have not been issued.
Current EU guidance: there is currently very little EU guidance that refers expressly to any social media channel, says Tim Worden from Taylor Wessing. Many of the risks for pharma companies engaging in social media channels in the EU are the same as those in the US, such as outside-of-licence references. However, the EU prohibition on the advertising of prescription-only medicines to consumers adds a further level of risk compared to the US position.
The UK’s Prescription Medicines Code of Practice Authority (PMCPA) – which is responsible for administering the Association of the British Pharmaceutical Industry’s Code of Practice for the Promotion of Prescription-Only Medicines (the UK Code) – has issued some brief guidance on blogs. The guidance states that if a pharma company were to sponsor a blog about a medicine or a therapy area, it would need to ensure that all information contributed to the blog complied with the UK Code. In other words, it would need to pre-vet all UGC on the blog. Tim goes into much more detail in his blog post, but essentially he believes that the EU is unlikely to provide any further substantial guidance until the FDA issues its guidance on pharma, the internet and social media. Even once the FDA guidance emerges, there will be a period of review when regulators and industry consider how that guidance might be translated into a different regulatory environment, in particular one which does not permit DTC.
As we know, pre-moderation on Facebook is not a possibility. Which leaves pharma with a choice: either withdraw their toes from the bath of social media (and lose the opportunties for interaction, marketing, product development and customer service that it provides, as well as depriving users of their source of information and community) or devote sufficient resource to round-the-clock vigilant moderation with clear paths for escalation should adverse effects be reported or misinformation be posted. If pharma companies withdraw from social networks, the conversations between users will still happen in other spaces: however, they will be fragmented across the internet, and it will be nigh on impossible to monitor. It will be interesting to see which of these paths is chosen.
(Thanks to Bliss H, moderator and community manager at eModeration, for her research) Read more...
