Guiding Pharma Through the Complexities of Social Media

Social media has become an integral part of modern communication. However, for pharmaceutical companies, using these platforms presents unique regulatory complexities that must be carefully navigated. As prescription medicines cannot be promoted directly to the public under UK law, pharmaceutical activity on social media warrants robust guidance to ensure compliance.

This article seeks to distil the most important principles from the recently updated ‘PMCPA Social Media Guidance 2023’ document for pharmaceutical companies operating in the UK. By examining the overarching considerations as well as specific use cases, we aim to provide an accessible review of how pharma can engage meaningfully with stakeholders online while respecting legislative boundaries.

Underpinning Principles

Before delving into particular social media activities, the Guidance outlines some foundational principles. As platforms are merely communication tools, all applicable laws and promotional codes fully apply regardless of the channel used. Importantly, pharma remains responsible for any material produced directly or via third parties, even if later distributed beyond contractual parameters.

Transparency is also stressed – interactions must make pharmaceutical involvement clear from the outset. Activities should avoid raising unfounded hopes and be factual/balanced without misleading. Information provision should reasonably match the needs/interests of target audiences in tone and format.

Employees too have personal responsibilities online. While maintaining privacy settings, pharma-linked posts could still ostensibly promote products depending on context. Companies are therefore advised to assume codes apply broadly to work-related online activity. Clear social media policies and regular training help mitigate such risks.

Specific Considerations

Turning to use cases, signposting versus direct posting is a crucial distinction. The former points interested stakeholders to vetted information requiring audience validation, avoiding direct promotion. Posts must not constitute advertising medicines lacking marketing authorisation.

With care, hashtags and tagging can connect online about general topics but naming products risks promotion. Similarly, hyperlinks must only direct readers to appropriate company/third party materials suited to the audience in question. Any adverse events mentioned require prompt pharmacovigilance procedures.

Correcting misinformation reactively through company reference materials is a nuanced area. Simply cross-referencing regulated documents may suffice but adding context risks introducing claims. Proactive information provision similarly treads close to promotion depending on how ‘investigational’ status is framed.

Accountability also extends to endorsing third party influencer materials. Only suitably qualified experts made fully aware of responsibilities should support certified activities limited to non-promotional stakeholder communications. Maintaining audit trails of online interactions forms part of demonstrating regulatory compliance here.

Specific Uses Considered

The guidance then examines common social media uses case-by-case. Corporate news/updates must remain non-product focused while clinical trial recruitment should avoid raising unrealistic hopes. Job postings demanding brand familiarity similarly risk covert promotion.

Disease awareness campaigns can name general symptoms but specific product mentions tend to promote use. Patient support videos are permissible with secure medical sign-in. Advertising events requires limiting those able to access promotional content as with meetings more broadly.

Investor/journalist communications do necessitate public social media ‘signposting’ but any linking content must remain tailored/gated. Professional profiles demand experience descriptions avoid coy references implying brand experience alone warrants the role.

Going Forward

As digitalisation increasingly transforms promotional models, balancing accessibility and responsibility will remain complex for pharma. However, by respecting these guiding principles, companies can thoughtfully harness the meaningful engagement opportunities social media affords while steering wide of promotional overreach or covert advertising contravening regulation.

Regularly reviewing activities and training staff appropriately to their roles also forms part of demonstrating commitment to compliant, stakeholder-centric digital strategies. As codes and platforms inevitably evolve, maintaining open dialogue across industry and with regulators ensures guidance stays pragmatic and protection of public health remains the priority when pharma socialises online.

In conclusion, observing both letter and spirit of the law underpins use of any new communication channel. By grounding online activity firmly in these compliance fundamentals, pharmaceutical stakeholders can confidently harness social’s benefits to progress important health discussions online. Moving forward together constructively, industry and regulators can adapt guidance smoothly to emerging realities – prioritising patients throughout the digital transition.

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Reference(s)

1. https://www.pmcpa.org.uk/media/x2pbqzy1/pmcpa-social-media-guidance-2023.pdf

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