The International Federation of Pharmaceutical Manufacturers and Associations (IFPMA) and the European Federation of Pharmaceutical Industries and Associations (EFPIA) recently published a joint guidance note for pharmaceutical companies using social media and digital media channels (Guidance).
Due to the increasing use of new communication channels, any information shared through social media and digital platforms (together Digital Channels) may reach a worldwide audience. Companies may be responsible for all content on Digital Channels when such content is initiated, influenced, branded, or sponsored by the company or a third party acting on its behalf. Hence, the Guidance serves as a non-binding resource that helps the pharmaceutical industry understand what is appropriate when communicating to the public, HCPs, HCOs, POs, and other stakeholders.
Specifically, the Guidance:
1. Describes principles applicable to communications on Digital Channels, including:
- Not using Digital Channels to engage in the improper promotion of pharmaceutical products, including not advertising medicines off-label;
- Complying with applicable laws on direct to consumer advertising and restricting access to the appropriate audience if needed (e.g., HCP only);
- Sharing truthful, non-misleading, balanced, current, and accurate content;
- Being transparent about the materials and contents on Digital Channels;
- Clearly stating the involvement of the company when a third party acting on company’s behalf provides content on social media;
- Processing personal data in compliance with applicable laws.
2. Helps companies identify responsibilities for content on Digital Channels and adopt relevant procedures, including:
- Measures to assess and verify adequate IT security of Digital Channels;
- Procedures to review, monitor, moderate, and delete activities, contents, and materials on Digital Channels and ensure compliance with applicable law;
- Appropriate training to employees regarding Digital Channels, as companies may be held responsible for their employees’ social media activities;
- Policies or procedures and/or employee training to meet their pharmacovigilance responsibilities.
3. Describes the general use of different types of Digital Channels, including websites, social media platforms, blogs, podcasts, webinars, direct channels, and discussion forums, and specifies that:
- Companies should keep information on Digital Channels up-to-date and display the date posted or updated;
- The use of keyword optimization should be appropriate for the intended audience and avoid unauthorized promotion to the public;
- Companies should make clear their role when sponsoring website contents by third parties and using blogs;
- Linked websites or blogs may not promote prescription medicines to the public in jurisdictions where this is not permitted;
- Companies should take care when using platforms that limit or restrict the ability to monitor or access comments (e.g., 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 opinion leaders, including:
- Engaging with influencers requires subtle and careful evaluation;
- Assessing the risk that digital content is perceived as improper promotion;
- Considering and documenting a rationale for engaging with influencers and digital opinion leaders (HCPs and non-HCPs) to avoid the risk of undue influence on HCPs, patients, and vulnerable groups;
- Remuneration should be appropriate and reasonable. Companies are encouraged to establish a methodology for calculating FMV rates;
- Disclosing transparency of relationships with influencers (e.g., via disclaimers) and any transfer of value to influencers, where required by applicable laws;
- Evaluating implementing guidelines or rules governing engagements with influencers.