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PAAB Offers Guidance on Regulatory Social Media Thought Process

Eye for Pharma organized the 1st eMarketing Canada conference, which was held in Toronto, on November 1-2 2010.

Patrick Massad (Chief Review Officer at the PAAB, Pharmaceutical Advertising Advisory Board) presented an algorithm to facilitate the regulatory thought process when planning a social media promotional activity.  Here is the suggested algorithm:

1) Is this advertising?

2) Who is the intended audience?

3) What restrictions should I consider for this audience with respect to disease and product schedules?

4) What mechanism will I use to limit access to that audience?

5) What is the sponsor’s tolerance for uncertainty & risk?

6) How will I align the site with this tolerance level?

7) What are the regulatory consequences of adding and/or linking other tools/content to my site?


Here are some highlights of Patrick’s presentation with regards to the very 1st step to detemine if tactic in mind is advertising or not:

Health Canada’s definition of advertising is as follows:  “any representation by any means whatever for the purpose of promoting directly or indirectly the sale or disposal of any food, drug, cosmetic or device” (as per section 2 of Food Drugs Act).

If this does not help to answer the question about whether the promotion is advertising or not, you can then refer to Health Canada’s policy document “The Distinction Between Advertising and Other Activities”, which lists the following 7 questions:

•What is the context in which the message is disseminated?
•Who are the primary and secondary audiences?
•Who delivers the message (the provider)?
•Who sponsors the message and how?
•What influence does the drug manufacturer have on the message content?
•What is the content of the message?
•With what frequency is the message delivered?

By answering these questions, the intent of the promotion becomes clearer as to whether the tactic is advertising or informational.

The intented audience and type of drug will determine which regulatory body needs to be consulted.  See this article here if you need assistance to determine which Canadian regulatory body to consult for your promotional campaign.

For more information about PAAB guidelines regarding social media, see Highlights from “Social Media Marketing in Pharma: What Works in Canada”

What do you think of this algorithm?  Would you add, delete or change any of the suggested steps?  Please leave a comment below.

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7 Responses

  1. […] This post was mentioned on Twitter by Gwendolyn Janssen, Nat Bourre. Nat Bourre said: Canadian pharma advertising regulatory body offers guidance on regulatory social media thought process. http://bit.ly/bR6Us1 #hcsmca #hcsm […]

  2. What do you think PAAB would say if we changed all occurrences of the word “message” to read “conversation”?

    What is always missing in guidelines (perhaps necessarily) is the other party in the conversation. The regulatory imbalance renders one party dumb while the other can speak freely with little regard to consequences. This, coupled with a lack of understanding of the rules, means that Pharma can appear aloof and unresponsive even when it most wants to engage.

    There are no glib answers to this, PAAB and Health Canada can’t just set aside the regulations and guidelines for social media because they are inconvenient, but it feels like more thinking needs to go into this.

    • Thanks Brad. It would be fantastic to allow more engagement and conversation. I would be happy to see regulations move that way as well. Unfortunately, I doubt that will happen anytime soon.

  3. This algorithm helps within the confines of the current, albeit outdated regulatory framework.

    I believe the first question gums up the whole works. By its very nature social media will always be advertising according to the Health Canada definition.

    HC needs to look hard at social media as a new communications experience for consumers that can’t simply be defined as purely promotional or purely informational. Consumers don’t care about that. They care that they can find the right information at the right time in the right way. If they are informing themselves about their treatment options they want to look at manufacturer’s information, patient groups, news, journals in order to form an opinion.

    How do we get the regulators to look at regulations for social media so that it can serve the best interest’s of the consumer?

    • That’s a great question Dave. Does the industry need to put together a task force to tackle this? Has this been attempted before? I will try to do a bit of digging around on this and will post something in the near future.

      • There definitely needs to be a task force. Social media strategists, agencies, doctors, pharma manufacturers, regulators all need to participate in defining the new rules.

  4. […] earlier this month, they presented even more guidance at the Eye For Pharma eMarketing Canada conference.  Just yesterday, they made their slides from the conference available on the PAAB website: PAAB […]

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