Is PAAB Doing a Good Job in Educating us on Social Media Regs in Canada?

Several months ago, the PAAB (Pharmaceutical Advertising Advisory Board) held 3 social media marketing sessions called “Social Media Marketing in Pharma: What Works in Canada”, twice in Toronto and once in Montreal, where they provided some of their insights on Canadian regulations regarding pharmaceutical social media marketing.  This meeting even had a representative from Health Canada as a panel member.

Then 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 Guidance on Social Media Marketing (61 slides). Enable audio on your computer as each slide has audio. The audio track on each slide is by Patrick Massad (Chief Review Officer at the PAAB).  Beware – the file is huge.  It slowed my computer down for several minutes.  But once you go through the slides and audio, you will find that it is full of valuable information, some of which was not presented at the recent eMarketing conference due to lack of time.

The PAAB has also made itself more available to the Canadian pharma community by setting up a LinkedIn, FaceBook and Twitter profile.  The PAAB has been using these avenues to not only update the industry on PAAB activities, but also to share information about social media from other countries.  On Twitter, the PAAB even posted a request for people to join one of their social networs and to start a discussion.

As far as I know, the level of outreach by the PAAB to the pharma industry with regards to guidance on the regulations that impact social media marketing is the first of its kind worldwide.  Please correct me if this is inaccurate.  I am aware of the FDA meetings held a while back, but so far, no guidance has been made available since those meetings.

Whether we like the regulations or not, and whether we feel the regulations are doing justice to the mantra of social media being open for engagement by all stakeholders, we have to give credit to the PAAB for their efforts in helping the Canadian pharma industry understand what we can and cannot do within the legal framework.  I am not a fan of the current Rx DTC regulations in Canada.  They are outdated, and I would like to see these regulations re-visited and modified.  But I don’t blame the PAAB for those regulations.  They did not make the rules.  They just help us work within them.

The only recommendation that I would have for the PAAB (and Rx&D as well for that matter), is to include something about social media guidelines as part of their overall set of guidelines.  Perhaps that is in the works and I am just not aware.

Do you think the PAAB is doing a good job in educating the Canadian pharmaceutical industry on how to apply current regulations to social media campaigns?  Do you have any suggestions for them to improve their outreach to the industry?

Disclaimer:  I have been involved with the PAAB on various social media activities, but this post is my personal opinion.  The PAAB has not had any input or influence in the content of this article.

Stay in touch,
Natalie

Connect with me on the following networks:
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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?

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2) Who is the intended audience?

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

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

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

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

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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.

Stay in touch,
Natalie

Connect with me on the following networks:
FaceBook, Twitter, LinkedIn

FaceBook Healthcare-Related Ads, Plus 2 from Pharma (March 8-21 2010)

Here is my latest post with various FaceBook healthcare-related ads that were targeted to my profile from March 8-21 2010.  Finally, there were a couple of ads from pharma companies.  One (from the U.S.), which is looking for job applicants, and the other (from Chile), which appears to be trying to sell their products in other countries.  It’s a start!

Previous posts on FaceBook healthcare-related ads:

• from Feb 6-18 2010 here
• from Jan 25 to Feb 5 2010 here
• from Feb 19 to Mar 7 2010 here

I also found an interesting healthcare-related ad on YouTube.  Since I do not see healthcare-related ads very often on YouTube, hence no need to start a new category, I decided to add it to this post.

Obviously there are many more of these types of ads on FaceBook, but these are the ones that have appeared on my specific profile.  This is by no means an endorsement of any of the products or services depicted, nor is it a critique of the ads themselves.

Feel free to critique any of these FaceBook (or YouTube) healthcare-related ads in the comments section.

Stay in touch,
Natalie

Connect with me on the following networks:
FaceBook, Twitter, LinkedIn

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Here is the YouTube healthcare-related ad. The ad changes after a few seconds, so I took a snapshot of both the first and second part of the ad, hence the two pics on top of each other;

The following are all FaceBook healthcare-related ads, except for the one about running your own hospital.  That one is just an ad for an online FaceBook hospital game, but I thought some readers might find it interesting.  Enjoy!

Canadian Pharma/Healthcare Regulatory Guideline Revisions – Jan 2010

Love them or hate them, as a medical marketer, you have a ton of regulatory guidelines to follow.  And they seem to change on a regular basis (some guidelines change more frequently than others).  In this blog post, you will find a list of some of the Canadian healthcare guidelines with links that will lead you to the document(s) of interest. The only revisions that took place in January 2010 are in the Rx&D code (see below for details of these changes).  A few other revisions for other sets of guidelines are expected over the next couple of months.  Although the details on the other revisions have not been shared with me, I made a note of when the revisions are expected to take place.

NOTE: If you have marketing collaterals or campaigns that need pre-clearance, but you are not sure which regulatory body to contact, take a look at yesterday’s post; Algorithm on choosing the appropriate Canadian healthcare regulatory guidelines.

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New 2010 Rx&D Code of Ethical Practices (not yet posted on the Rx&D website, but coming soon). Here’s a peak at the upcoming changes.  Only section 15 has been revised in the 2010 code:

Section 15.4 Penalties

• In 2009, the 1st, 2nd and 3rd code infractions were published in the Rx&D Update.  As of 2010, these infractions will be published on the Rx&D website.  All postings will remain on the website for 24 months from the date of the final decision.

New section 15.4.1 Compliance Statement (3 statements as part of this new section)

• Within ninety (90) days of the final decision date with respect to any Code infraction, the Member must clearly indicate in writing to Rx&D that they have halted the activity or otherwise addressed the issue that caused the infraction. A copy of this compliance statement will be posted on the Rx&D website with the relevant decision of the IPRC.

• In the event that Rx&D determines that the Member has not complied with this requirement, the Member will be deemed to have deliberately contravened one of the Guiding Principles, and the penalties set out in Section 15.3, 15.5.1 and 15.5.2 will apply.

• In exceptional circumstances, a Member, acting in good faith, may believe that more than ninety (90) days will be required to comply with this Section 15.4.1. In this case, the Member must file a written extension request with Rx&D within ten (10) days of the decision date, providing a detailed supporting rationale for the request, and an estimate of the time required. Rx&D will forward the extension request to the IPRC who will evaluate the extension request and make a recommendation to the Rx&D Executive Committee (EC) within ten (10) days of its receipt. The EC, in its sole discretion, may elect to grant such an extension to the Member.

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Pharmaceutical Advertising Advisory Board (PAAB)

• Several supplementary guidelines to the PAAB code exist.  A recent example; “Guidance for Advertising/Promotional Systems (APS) Which Are Openly Visible in Healthcare Professional (HCP) – Patient Interaction Areas”
• Recently, PAAB has implemented the Health Canada document Interim Guidance on Fair Balance in Direct-to-Consumer Advertising of Vaccines
• You might also want to look at the PMCQ website for a list 100+ PAAB FAQs.
• No changes in the PAAB code.
• No changes in prescription DTCA guidelines
  

Canadian Association of Medical Publishers
It does not appear as though any new guidelines have been posted, since at the bottom of the CAMP advertising guidelines page, the last update appears to have been on May 11 2009.

MEDEC-Canada’s Medical Technology Companies
Revisions scheduled for March 2010.

Consumer Health Products Canada (previously NDMAC)
No changes, but expect some to come once their new website (along with new organizational name) gets launched within the next month or so.

Advertising Standards Canada (ASC)

• Any change in ASC guidelines would be from a result of changes with the Health Canada documents.  Since there have been no changes for the Health Canada documents, there have not been any changes for the ‘Consumer Drug Advertising Clearance’ documents of either the Prescription drugs or the Non-prescription / Natural health products (see the two boxes on the left of the ASC screen which allow you to choose the documents required based on the product type).

Health Canada’s documents regarding direct-to-consumer (DTC) advertising of prescription drugs

• Note that both PAAB and the ASC can provide an advisory opinion on DTC collaterals and campaigns.
• No changes for any of the following documents.

• The Distinction Between Advertising and Other Activities
• Advertising Campaigns of Branded and Un-branded Messages
• Product Package Representations in Branded Prescription Drug Reminder Ads Directed to Consumers

Health Canada’s documents regarding direct-to-consumer (DTC) advertising of non-prescription drugs

• ASC and MIJO can provide preclearance services with respect to consumer advertising of non-prescription drugs and natural health products.
• No changes for any of the following documents.

• Consumer Advertising Guidelines for Marketed Health Products (for non-prescription drugs, including natural health products)
• Therapeutic Comparative Advertising: Directive and Guidance Document
• Principles for Claims Relating to Comparison of Non-therapeutic Aspects of Non-prescription Drug Products

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Note that I am not a pharmaceutical regulatory expert.  I am providing these resources as a service to my blog’s readers.  If you have specific regulatory questions, please contact the appropriate organization.

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Stay in touch,
Natalie

Connect with me on the following networks:
FaceBook, Twitter, LinkedIn

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Cold-FX: A Fun Canadian Healthcare Social Media Campaign

More and more Canadian healthcare companies see the benefit of leveraging social media for their businesses.  Here is a really interesting example that caught my attention because it encompasses what is critical for a successful social media campaign:  lots of interaction and viral effectiveness.  It also appears to follow the Canadian regulatory guidelines.  Learn more about the Cold-FX social media campaign here.

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Afexa Life Sciences, a medium-sized Canadian company with a variety of over-the-counter (OTC) products, has launched a fun social media campaign in November 2009 to leverage their sponsorship of the 2010 Winter Games in Vancouver, BC (“Cold-FX: Official cold and flu remedy of the 2010 Winter Games”).  Cold-FX is the brand that is sponsoring the Olympics and is the backbone of this fun social media campaign.

There are 3 components to this campaign;

1)      a FaceBook fan page with over 800 fans within 3 months and most importantly a high level of engagement by the fans,

2)      a Twitter account which has grown in popularity since their existence on Twitter as of September 2009, and

3)      a very popular  ‘Athlete of the Year’ video which can be customized with your name, or that of a friend.  The video was launched on November 19th and as of December 4, has already been viewed over 28,000 times (Source:  Data on file, Afexa Life Sciences).

If you look through the FaceBook and Twitter posts by Afexa, you will notice that there is no mention of the brand Cold-FX.  All of the posts by Afexa are related to their Olympics Trivia game.

Moreover, the ‘Athlete of the Year’ video has only a minimal amount of branding as well, as shown in the photo below.

Cold-FX 'Athlete of the Year' viral video

(… and for the record, the only way that I could be recognized for any athletic skills whatsoever would be if running after a 2-year old while talking on the phone with a client and taking notes of our discussion were a sport … thank goodness I have the most understanding and wonderful clients in the world  …)

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On Friday December 4^th, I had an opportunity to speak with Justin Jones (Director Digital Strategy) and Hardeep Gosal (Online Community Manager) of Afexa Life Sciences to discuss their Cold-FX social media campaign.  Here are a few highlights of our discussion:

• New to social media:  The Cold-FX campaign is the first social media campaign for the company.

• Taking small steps at a time:  They started by monitoring to find out where their consumers were online, what they were saying about the brand, the sentiments of their comments and the reach of forwarded messages.

• Deliberately being conservative: The main objective of the campaign is to build relationships with the consumers, therefore messages are kept neutral and non-branded to give the consumers an opportunity to get to know the company and feel comfortable to communicate with them.

The snapshot below was taken of the Cold-FX Twitter profile at the end of the day on December 7 2009.  It demonstrates the neutral, non-branded messages being posted by the company.  As for the design of the Twitter profile, the only branding consists of the “Cold-FX” name found on the left and the right side of the screens.

Cold-FX Twitter profile

• Selling the idea to senior management:  1) Showed them the analysis of a full year’s worth of social media monitoring, and 2) presented a variety of real cases.

• Building up a follower-base is a long process but well worth the time and effort.

• Company wide initiative:

• • Approximately 16 months prior to the launch of the social media campaign, all employees had an opportunity to discuss their feelings, knowledge and comfort level with social media.  Justin captured the corporation’s learning culture by stating that:  “The more we educate our employees about visual technologies, internet, mobile technology, social media, the more internal support we are likely to gain in the months ahead for our social media campaign.”
  • Training then took place to educate our employees on the use of social media.
  • Firewalls do not block employees from logging onto social media networks at work, although there is a social media policy in place to avoid abuse.
  • As part of their social media policy, Afexa Life Sciences’ employees are encouraged to not talk about product or anything financial.
  • Followers’ engagement with the company via social networks is creating a lot of positive energy and excitement in the organization, and employees are motivated by this.

• Biggest challenge in managing a social media campaign:  Being new to social media, the organization expects to make mistakes and learn from them.  However, the social networks frequently change the landscape, rules and regulations.  To work through these changes, the organization is partnering with suppliers who maintain a close pulse on upcoming changes within the various social networks in order to help predict and manage upcoming changes.

The FaceBook fan page “wall” snapshot below describes the quick change that the Afexa Life Sciences team needed to implement to stay within FaceBook’s revised contest policy:

Afexa reacted quickly by launching a FaceBook application on December 9 2009, which now allows them to continue their trivia contest on FaceBook while staying within the FaceBook policies.  Just check out the ‘Trivia Contest’ tab on their FaceBook page and you will be brought to the new application.

• Measuring ROI:  Be clear on your objective for implementing a social media tactic and determine ROI measurements based on that information.  Afexa’s main objective for the Cold-FX social media campaign is not financial.  Instead, the main objective is to build relationships with consumers.  Some of the measurements for this campaign consist of;
  • Number of followers
  • Frequency of engagement
  • Sentiments of consumer communications online
  • Click-through to the Cold-FX website

• 5 Key Learnings from Afexa Life Sciences:

1. Leverage monitoring tools to see what people are saying about your brand and the general sentiment of their communications, as well as identify demographics of the consumers who are talking about your brand online and what platforms they are using.
2. Stay focused on 1 or 2 social media platforms rather than all of them.  Go through the experience with the selected platforms, learn from it, and then scale onto other platforms if your objectives direct you that way.
3. Leverage partners who are dealing with some of the social networks that your brand is involved with.  Dealing with a company that has an idea of upcoming policies will save you a lot of time and a lot of money.
4. From an internal organizational perspective, take the time to carefully draft a social media policy and respect everybody’s level of comfort with social media when presenting internally.
5. Embrace social media.  Social media is here whether we like it or agree with it.  Google Sidewiki is a perfect example; people can comment on your brands or organization whether you give them the platform to do so or not.

Hardeep summed it up nicely with the following comment:

“The conversation is already happening with your product, so why not get involved.  Companies are often afraid of negative feedback, but we have found that brand advocates balance the conversation with positive comments.  Brand advocates -see who they are and develop relationships with them.”

Regulatory considerations for the Cold-FX social media campaign: Cold-FX is approved in Canada as a Natural Health Product, therefore it has more flexibility than a prescription product in terms of regulatory guidelines in its promotions.  I asked Ray Chepesiuk, the PAAB Commissioner, for his regulatory insights with regards to this campaign.  Here was his response;

“The Cold-FX social media campaign is brilliant and appears to be well within the regulatory guidelines.  You can do a lot more with consumers with an NPN product from a regulatory perspective because you can actually advertise with claims.  You can talk about your drug, but the only caution is to make sure that fair balance is included and indications stated correctly in accordance with the product’s license.  It appears that Afexa Life Sciences have respected the linkage policies of Health Canada in this campaign.  If there is promotion, they must follow section 9(1) of the Health Canada’s Food and Drugs Act.”

Kudos to Afexa Life Sciences for taking on this initiative with passion and enthusiasm, and for giving a chance to their consumers to have so much fun with the campaign.

GIVEAWAY: Afexa Life Sciences has kindly offered to give away 5 COLD-FX Vancouver 2010 Olympic Winter Games Hockey 3-Pin Sets to those who write comments about this post.  For those who decide to write a comment, I will be in touch with you to gather your shipping information (so please do not include that information as part of the comment).  If more than 5 people write comments, then we’ll have to make it a draw in which case everybody who writes a comment will be given a number (ie. the 1st to write a post is assigned the number ‘1’, and so on) and then will be randomly selected with the use of the random number generator Random.org. Deadline is Wednesday December 16th, 11:59 pm.  Draw (if required depending on number of comments) will take place on Thursday December 17^th (to give us enough time to ship you the pin-sets in time for the holidays if you plan on giving as a gift).

DISCLOSURE: Afexa Life Sciences has not paid me to write this article, is not a client and has not requested a business pitch from me.

Stay in touch,
Natalie

Connect with me on the following networks:
FaceBook, Twitter, LinkedIn

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Canada’s Online Health Check – Online Hotspots to Connect with Canadian Pharma Professionals

Last week, I shared with you the results of a recent survey that looked at some high-level trends of where and how Canadian pharmaceutical professionals are using social networks.

Since networking and collaborating with colleagues can have a significant impact on our professional lives, I wanted to follow-up on my previous post with highlights of a few groups within LinkedIn, FaceBook and Twitter that may assist Canadian pharmaceutical professionals to find and network with one another.  Note that some of these groups offer greater networking opportunities than others, but I will leave it to you to check them out and decide which is best for you.

GIVEAWAY: In the spirit of networking and sharing, I have saved 6 Google Wave invitations to share with 6 Canadian pharma colleagues (client or agency, but must be involved in the Canadian pharmaceutical industry).  Google Wave is a collaborative online tool, which at the moment is only available to those who are invited by somebody already on the network.  How to enter this giveaway contest?  Write a comment on this post.  Since I only have 6 invitations left, if more than 6 people write a comment, then we’ll have to make it a draw in which case everybody who writes a comment will be given a number (ie. the 1st to write a post is assigned the number ‘1’, and so on) and then will be randomly selected with the use of the random number generator Random.org.  The monetary value of this giveaway:  a big, fat $0.00 .  So why am I bothering? The intent is to share this tool with others who truly want to collaborate with their colleagues online.  What better way to find out who these people are than to just ask them to ‘raise their hand’ online.  Plus, once you are on Google Wave, then you get a bunch of invitations to send to your friends as well.  What a great way to connect, share and collaborate with one another.  Deadline is Sunday December 13th, 11:59 pm.  Draw (if required depending on number of comments) and invitations will take place on Monday December 14th.

LinkedIn:

Biotech and Bioscience in Canada

Canadian Health Informatics

eCHE and eMarketing Insider

Market Access for Canadian Pharma

Ontario Pharmaceutical Marketing Association (OPMA)

Pharmaceutical, Biotech & Medical Devices Jobs in Canada

The PAAB

FaceBook:

Biotech/Pharma/Medical Device Careers in the United States & Canada

The PAAB

Twitter:
About a month ago, Twitter added a new “list” feature.  As part of these lists, Twitter users (tweeps) can select certain people that they are following as part of their lists and make the lists public.  You can give a name to the list, so tweeps who see your list will have an idea what it is about.  I have put together a ‘Canadian Pharma’ list that you may wish to peruse or follow.

The development of this list is ongoing as I find new people who meet the criteria and also as Canadian pharma folks join Twitter.  If you work in the Canadian pharma industry and are on Twitter but not on my list, please make sure to send me your username and I will add you to it.

Here are a few resources to help you find your Canadian pharma colleagues on Twitter:

1)      To find people based on their bio, you can use TweepSearch.com and insert the keywords that you are looking for.  This system is helpful, but not perfect because the search results will depend on the words used in people’s bio.  So if you are on Twitter and want to be found and recognized for certain keywords (ie. ‘pharma marketing’), make sure that they are part of your bio… and this includes your location too.  If somebody is searching for a ‘pharma marketing’ tweep in Canada, but your location is left blank, you will not show up as part of their search.

2)      To find people based on the content of the posts that they publish (tweets), you can either do a search directly in Twitter or use one of many search engines that track tweets.  I like to use IceRocket.com and WeFollow.com for this purpose, but there are many other sites that provide a similar type of search at no cost.

Although this is not a Canadian-specific resource, you might be interested in following pharma companies on Twitter.  If so, you can start by checking out Ignite Health’s dashboard.  In fact, the cool thing about this dashboard is that even if you are not on Twitter, you can still follow the more recent posts that are written by these pharma companies directly from the dashboard.

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This is just a sample of the many groups that may be of interest to a Canadian pharmaceutical professional.  There is also a plethora of social networks with an international focus that might offer excellent networking opportunities with both Canadian and international colleagues (for example, just search “pharma” for LinkedIn groups and the list goes on and on).

If you know of other Canadian groups that were not mentioned in this post, but you think that Canadian pharma professionals would be able to connect and collaborate with each other by joining them, please leave a comment with the name and URL for the group.  And remember that your comment will be considered as an entry in the Google Wave invitation giveaway contest (as described above).

Stay in touch,
Natalie

Connect with me on the following networks:
FaceBook, Twitter, LinkedIn

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Canada’s Online Health Check – More Proof that Canadians of all Ages are Active on Social Networks

I was just about to shut down my e-mail as it was almost midnight, but I saw that a new Groundswell post had been submitted. As I am the curious type, especially when it comes to social media news, I had to open it right away. Am I ever glad that I did because it focused on some great news that would get any Canadian marketer excited; the Social Technographics Profile tool now includes the option to select CANADA. So bedtime was pushed out further as I was so thrilled about this new feature that I had to check it out right away.

Background: The Social Technographics Ladder explains the level of activity on social media by various market segments. As you go up the ladder, each group becomes more and more involved in social media activities. The Social Technographics Ladder you see below is an overview of Canadians’ (all ages, both genders) use of social networks (snapshot taken on December 3 2009).

Pharmaceutical and healthcare companies frequently ask whether their target market, especially if this consists of an older audience, is involved in social media. Now they have the answer, and it is a resounding “YES” for all age groups and both genders.

Let’s compare Canadian women and men aged 55 years and older;

On the lower end of the spectrum, there are 42% of Canadian females and 38% of Canadian males aged 55+ that are currently inactive, therefore not accessible via social networks. However, 42% of Canadian females and 50% of Canadian males aged 55+ are watching, reading and listening to what is happening on various social networks. As you keep going up the Social Technographics Ladder, you see that our Canadian seniors (and I use this term only because it is the highest age group you can segment by in this particular application) are definitely involved in social media at some level. It will be interesting to see the chart for this age group change over the years as the more active younger generations grow older.

Add that information to the North American Technographics Benchmark Survey of 2008, and you have the basis for a pretty good discussion about whether healthcare marketers should consider a social media tactic for their specific target audience (Source: Forrester Inc. Research;  blogs.forrester.com ─ April 22, 2009).

So go ahead and play with the Social Technographics Profile application to see where your target market fits in (and check for yourself as well). It is fun, interesting and a valuable tool for all marketers.

Stay in touch,
Nat

Marketing 4 Health Inc.
Medical Marketing and Social Media Consultant

Connect with me on the following networks:
FaceBook, Twitter, LinkedIn

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