Harnessing the power of social media in the pharma industry: our 3 takeaways from the new PMCPA guidance
The long-awaited Prescription Medicines Code of Practice Authority (PMCPA) social media guidance, outlining the principles for the appropriate use of social media platforms by pharmaceutical companies in the UK, is finally here.But what does this mean for pharma marketers and comms leads, and what changes does it bring in a field that’s traditionally been beset by uncertainty and hesitation? Will pharma companies be better equipped to engage with their audiences on these important channels, in a compliant and yet authentic way, as their stakeholders increasingly expect them to?
We have dug deeper into the new guidance and summarised our key takeaways.
But first things first. Where does this new guidance come from and what changes does it bring compared to the code of the Association of the British Pharmaceutical Industry (ABPI), that pharma companies abide by?
This social media guidance has been long awaited by pharma marketers, communications teams and medical signatories, and for a good reason: it is the result of a mammoth consultation effort, led by the PMCPA (the self-regulatory body that administers the ABPI Code) and involving the Medicines and Healthcare products Regulatory Agency (MHRA), the ABPI, and pharmaceutical companies. It also takes into consideration the recently published guidance of the European Federation of Pharmaceutical Industries and Associations (EFPIA) and the International Federation of Pharmaceutical Manufacturers & Associations (IFPMA).
The key principles of the ABPI code do not change, as the guidance supplements the code providing informal advice. But the PMCPA made a clear effort to develop an easier-to-digest and solution-oriented guidance, with helpful checklists and examples. While some grey areas and a general sense of caution remain, this document will hopefully give more confidence to the communications and approval teams when approaching any new social media activity. The document also recognises that social media platforms are constantly evolving, and as such, this cannot be a definitive and exhaustive guide, but is rather meant to set some core principles.
Social media is not the place for product news
Due to their own nature, social media channels reach a wide and global audience, and the PMCPA reinforces that they should be considered as aimed at the general public. While the guidance recognises that some platforms allow the set-up of closed groups, which could be used to reach healthcare professionals, media or investors (with the due validations), the general recommendation is to avoid any mention of prescription-only medications on open platforms. The EFPIA code goes even further, stating that any brand or generic name, with or without indication, is a form of promotion to the public and therefore prohibited.
No place for the blanket distribution of press releases announcing data or regulatory milestones on Twitter or LinkedIn, then. But the guidance goes further, noting that even the use of social media to alert health professionals about the publication of a study on a medicinal product could be considered promotional.
So what type of content can pharma companies share on their digital platforms?
The PMCPA gives the green light, as long as the right safeguards are in place and no products/pipeline assets are mentioned, to a broad range of corporate activities, such as new executive appointments, corporate partnerships and acquisitions, employee recognition, company awards and job ads.
Disease awareness activities are also well placed on digital channels, as long as the content is educational and invites the audience to seek medical advice without promoting any medicine. However, care must be taken when a company’s product is the only medicine for a certain condition or symptom and the PMCPA reminds that all content, including liking and resharing of patient organisations’ posts, requires certification.
Digital channels can also be used for patient support programmes. For example, a video explaining how to inject a specific drug can be hosted on a secure section of YouTube and the dedicated URL can be shared with patients who have been prescribed that medicine.
Signposting and targeted ads are your option to reach media and HCPs with dedicated messages
While posting promotional messages on social media is prohibited, the PMCPA guidance suggests a way forward for using digital platforms to reach specific audiences who might have an interest in product news and education, such as journalists, investors and doctors. That’s where signposting and targeted ads come into play.
Signposting means alerting readers that audience-specific information is available, noting the nature of the information and who it is intended for, and only allowing access upon validation.
Pharma companies are used to hosting dedicated media, investors or HCPs sections on their corporate websites, which are only accessible upon self-validation. A social media post could therefore be used to alert followers that a new press release is available and point to the dedicated section of the corporate website. The post should be sufficiently clear for all followers to determine whether that information applies to them or not, but should not constitute a promotion of a medicine to the public. For example, this could read: For UK journalists only: a press release with new data in oncology is available at [link to web page requiring validation]
Signposting could equally be used to invite HCPs to register for a promotional meeting, indicating that this is intended for HCPs only and will include product promotion, without mentioning any medicine. Any further details can be disclosed following validation.
Similarly, paid targeted ads could be an option to segment audiences, especially on LinkedIn where ads aimed at HCPs can be targeted based on job title, education and specialism. The PMCPA still recommends caution to ensure the ad is only visible to the intended audience and cannot be shared with members of the public.
The same approach could be taken to support clinical trial recruitment, with ads being carefully targeted to individuals who fulfil the criteria/demographics, as long as no unfounded hopes are raised and no products are mentioned.
A further option could be the set– up of a closed group, for example dedicated to journalists or investors, to share audience-specific content.
Pharma companies need stringent procedures and training
Throughout the guidance, the overarching principles of responsibility and transparency are clearly emphasised. Pharma companies are held responsible not only for their own social media materials and activities, but also for those of their employees and of any third parties acting on their behalf.
Pharma companies need to have clear procedures in place to review and monitor their social media channels, where Adverse Events (AE) could be discussed and inappropriate comments might require moderation. Community guidelines could help them to set boundaries and manage expectations within the online communities they nurture, so that inappropriate messages and behaviours can be promptly and successfully managed.
Social media has also opened the possibility to partner with influencers, who are experts in the condition they live with or treat, and can get important health messages across to the right audience. The new guidance provides some clarity in a field where pharma companies have traditionally felt nervous to engage.
Transparency is critical when working with third parties such as influencers, and the relationship with the pharmaceutical company must be made very clear at the outset. Contracts with third parties should deal comprehensively with ownership and control of materials, both during and after the contracted period. This includes ensuring contracted speakers and influencers are aware of the requirements of the ABPI Code. Pharmaceutical companies are also strongly advised to preview social media content from their third parties (agencies included, think awards announcements!) and are responsible for the certification of these posts.
The guidance also reinforces that the simple liking of a post, especially on LinkedIn, is essentially disseminating it to a wider audience and could result in promotion to the general public. Pharma companies should therefore invite their employees to act with caution when discussing their professional role and/or their company’s commercial and research interests on social media. Internal training and clear standard operating procedures (SOPs) are paramount to mitigate risks.
In a nutshell, while the new guidance contributes to clarifying some historically grey areas, it still invites caution, careful planning and close monitoring of all social media activities.
That said, social media is an important channel to use when seeking to reach audiences. Whilst it may feel like it can be ‘too difficult and risky’ to explore, we need to think more about what our audiences want and need. Well-crafted, balanced information which adheres to the Code is going to support our audiences and build reputation for the pharma industry.
If you want to discuss how to create impactful, compliant social media programmes, just drop us a line at [email protected].