The International Federation of Pharmaceutical Manufacturers and Associations (IFPMA) and the European Federation of Pharmaceutical Industries and Associations (EFPIA) recently published a joint article the guidance note for pharmaceutical companies using social media and digital media channels (Tips).
Due to the increasing use of new communication channels, any information shared via social media and digital platforms (together Digital channels) can reach a global audience. Businesses can be responsible for any content on digital channels when that content is initiated, influenced, branded, or sponsored by the business or a third party acting on its behalf. Therefore, the Guidance serves as a non-binding resource that helps the pharmaceutical industry understand what is appropriate when communicating to the public, HCPs, HCOs, GPs and other stakeholders.
Specifically, the Guide:
1. Describes the principles applicable to communications over digital channelsincluding:
- Do not use digital channels to engage in inappropriate promotion of pharmaceutical products, including not advertising off-label drugs;
- Comply with applicable direct-to-consumer advertising laws and restrict access to the appropriate audience as necessary (e.g., HCP only);
- Share content that is truthful, not misleading, balanced, current and accurate;
- Be transparent about materials and content on digital channels;
- Clearly state the company’s involvement when a third party acting on the company’s behalf provides social media content;
- Processing of personal data in accordance with applicable laws.
2. Helps businesses identify responsibilities for content across digital channels and adopt relevant proceduresincluding:
- Measures to assess and verify the adequate IT security of digital channels;
- Procedures to review, monitor, moderate and remove activities, content and materials on the Digital Channels and ensure compliance with applicable law;
- Appropriate training of employees regarding digital channels, as companies can be held responsible for the activities of their employees on social media;
- Policies or procedures and/or employee training to fulfill their pharmacovigilance responsibilities.
3. Describes the general use of the different types of digital channelsincluding websites, social media platforms, blogs, podcasts, webinars, direct channels and discussion forums, and specifies that:
- Businesses must keep digital channel information up-to-date and display the date of publication or update;
- The use of keyword optimization should be appropriate for the intended audience and avoid unauthorized promotion to the audience;
- Companies should clarify their role when sponsoring third-party website content and using blogs;
- Linked websites or blogs may not promote prescription drugs to the public in jurisdictions where it is not permitted;
- Companies should exercise caution when using platforms that limit or restrict the ability to monitor or access feedback (eg, ephemeral and encrypted apps);
- The audience for podcasts and webinars should be well defined and targeted, and the content should be appropriate.
4. Provides specific guidelines when engaging with online influencers and digital thought leadersincluding:
- Engaging with influencers requires subtle and careful assessment;
- Assess the risk that digital content will be perceived as inappropriate promotion;
- Consider and document a rationale for engaging with digital influencers and thought leaders (HCPs and non-HCPs) to avoid the risk of undue influence on HCPs, patients, and vulnerable groups;
- Remuneration must be appropriate and reasonable. Companies are encouraged to establish a methodology for calculating FMV rates;
- Disclose transparency of relationships with influencers (for example, via disclaimers) and any transfer of value to influencers, where required by applicable laws;
- Evaluate the implementation of guidelines or rules governing engagement with influencers.