Health Canada has recently released a new clinical information portal that will provide Canadian consumers with easy access to the clinical information that is provided by manufacturers when submitting for approval of new drugs and medical devices. This includes clinical trials and study reports. Closer to the end of this article, you will find a video that walks you through the portal as it currently exists.
Currently, the site only has 1 drug and 1 medical device as part of the listing, but Health Canada is planning on including the clinical trials and study reports of new drugs 120 days (3 months) after the approval of their new drug submission. Proactive disclosure for medical devices will start in 2021.
With regards to existing drugs and medical devices, my understanding is that Health Canada will provide the clinical trial information upon request and will also add them to the portal as the requests roll in.
It’s clear what this means for consumers – they will have access to highly credible data sources related to their prescription drugs and the medical devices that are used as part of their diagnosis or treatment. This is a good thing, particularly since Canadians are bombarded by U.S. prescription drug ads which give a bunch of clinical information anyways.
But what does this mean for companies that market drugs and medical devices in Canada?
Should companies start to expect more or fewer medical inquiries? My personal guess is that it will increase overall but not by all that much because some consumers will find the information that they were looking for by themselves and will not need to contact the company. Otherwise may have even more questions after reading the documents. Let’s face it – supporting articles for drug product and medical device submissions are loaded with heavy-duty medical and pharmacological information. They will answer some questions and will definitely end up creating new ones as well. But questions about one’s health are good. We want and need our Canadian consumers to be well informed about their health so that they can make better decisions and choices for themselves and the ones they care for.
There might be more transparency about competitive launch dates based on the list of drugs or medical devices that are accessible to all. Market researchers and analysts already keep track of various competitive data, but this will be one more aspect to provide more in depth and credible information.
Once the database is more mature and robust, it will contain a lot of information. This will become pertinent for global pharmaceutical companies looking for sales opportunities in Canada. Before they launch or look for partners, they will be able to easily scope out the landscape in terms competitive activity.
Transparency and accuracy are critical in the era of digital information, so Health Canada made the right decision in moving in this direction, even though some will certainly disagree.
Let us know how you think this will change healthcare and medical marketing in Canada.
Whether you have ever tried to lose weight or not, most of us realize that there are peak times when people get motivated to take on the challenge. And here we are in January, the time when approximately 1/3 of Canadians resolve to work on their fitness levels and nutrition (Source: Statista, Leading New Year’s Resolutions according to Canadians in 2017).
Novo Nordisk Canada understands the mindset of their target audience for Saxenda®, a weight loss prescription medication, and they play to it very well through their evolving Saxenda® social media campaign. Below you will see how the Saxenda social media campaign started and how it evolved throughout the past 8 months.
May 2018: Laying down the foundation
Novo Nordisk Canada sponsored Facebook ads promoting the fact that obesity was now considered a chronic illness by several medical organizations. I only have screenshots of the French ads. This was a great starting point to lay down the foundation for their upcoming campaigns for both of their prescription weight loss products, Ozempic® and Saxenda® .
June 2018: Saxenda® Choose Change campaign
The Saxenda Choose Change campaign was launched on Facebook in June 2018. Novo Nordisk Canada was sponsoring several Facebook ads which were obviously targeted to healthcare professionals, with a call-to-action asking the healthcare professional to watch their 59-second video. The objective was to get healthcare professionals to start a discussion about obesity with the appropriate patients, with a message that obesity is a disease and is treatable.
The SaxendaChoose Change campaign was also targeted to overweight Canadians in a wide variety of Facebook ads, in both English and French. The ads were designed to increase awareness of Saxendaand encourage interested Canadians to speak with their primary care physician about it. With the frequent mentions of a resolution update, it appears that Novo Nordisk Canada was targeting patients who had tried to lose weight before but were unsuccessful. It appears that the Saxenda Choose Change campaign was meant to re-inspire these patients.
The Saxenda Facebook ads directed Canadians to www.Saxenda.ca where they can learn more about how to speak with their doctor about Saxenda and obtain a discount for their first box of Saxenda.
September 2018: Back to Saxenda® campaign
Other than January, September seems to be a symbolic time for new beginnings for many people since it is the beginning of a new school year, and Novo Nordisk Canada spun that into their Saxenda campaign with a play-on-words focused on back-to-school; Back to Saxenda and First day of Saxenda. They also maintained their Choose Change slogan for a few of their Facebook ads. As you can see, their ads continued to target overweight men as well as overweight women.
December 2018: Now is the new later campaign
Fully aware that many people wait for January to take a resolution to lose weight, Novo Nordisk Canada sponsored Facebook ads to motivate overweight Canadians to take action now and not wait until January. As marketers, we know how that last little push at year-end just might make the difference for a brand to reach its sales objectives for the year.
Late December 2018: Countdown to new year resolution
And my personal favorite part of this campaign evolution so far was when Novo Nordisk Canada sponsored Facebook ads for a 3-day countdown to the new year. A pharmaceutical company can have a bit of fun with its community just like a consumer company! Understandably, some brands do not have that luxury because of the type of disease that they are associated with, but for certain brands like weight loss prescription products, it works beautifully.
January 2019: The Saxenda® resolution campaign
Novo Nordisk Canada is again playing on people’s need for a fresh start by encouraging overweight Canadians to make a new year’s resolution to talk to their doctor about Saxenda.
Playing by the rules: Direct-to-Consumer (DTC) pharmaceutical advertising
Throughout the evolution of the Saxenda social media campaign, Novo Nordisk Canada played by the direct-to-consumer pharmaceutical advertising guidelines which state that you can only refer to the product name, price or quantity. You will notice that the ads targeted to patients mention the brand name Saxenda, but they do not mention any indication related to weight loss. In the ads targeted to healthcare professionals, they have to be careful because even though these ads are not intended for patients, it is possible for a consumer to see it so they must be treated as a direct-to-consumer pharmaceutical advertising ad. And they are! The ads either mention obesity or they mention the brand name Saxenda, but never both in the same ad.
Where to follow Novo Nordisk Canada:
You can find the Novo Nordisk Canada Facebook page here, although it is not used to communicate with the online community. Its main purpose is just to be the anchor page for Facebook ads, which has been a requirement of Facebook for the past year or so. However, their Twitter account posts more regularly, and you can find them on Twitter here.
Novo Nordisk Canada partnered with Media Platforms for their Saxenda® campaigns.
Saxenda® ads shown in this blog post are all owned by Novo Nordisk Canada.
Let us know what your thoughts are on the evolution of the Saxenda social media campaign in the comments below.
This week, a Facebook ad from the Council for Continuing Pharmaceutical Education (CCPE) appeared in my timeline, with the intention of promoting their new CCPE website. I have been following the CCPE Facebook page and CCPE LinkedIn business page for years and they are a quiet bunch on social media, so I was really excited to see that they had sponsored a post on Facebook. My guess is that they simply targeted their 74 Facebook followers. They may be testing their social media advertising opportunities.
At the time of writing this post, they did not have anything posted on their LinkedIn page and I could not find them on any other social media network. Unfortunately, they do not promote their presence on social media on their website. This might be because of their low activity on social media. Personally, I would like to see them more active on social media because their service is valuable and I think a lot of young, Canadian pharmaceutical sales representatives and marketers can be found on various social sites. Their presence probably reflects that of the general Canadian population for their age group.
Here is a screenshot of the ad that the CCPE posted:
Be sure to check out their new website, whether it is for yourself or more junior people that you are mentoring.
Marketers in every single industry have been hearing about the importance of artificial intelligence (AI), including pharmaceutical marketers. The major difference between the pharmaceutical industry and the others is that pharma is highly regulated in what it can say and do. So, is PAAB review required for chatbots? The answer is, of course, yes!
Whether a communication from a pharmaceutical company comes from an employee or a chatbot, the regulatory requirements must be treated the same;
For chatbots, the initial submission must include a detailed description of the model determining which scripts are used in which contexts (such that the underlying logic and model assumptions can be reviewed). Again, if applicable, A detailed description of how machine learning will take place must also be included.
Early Bird Special:
Book by September 28, 2018 and save $50
Here are the key learning objectives:
1) 2017-18 complaints & advice
Case studies from Health Canada and PAAB on public non-compliant communication materials and campaigns.
2) Real World Evidence
Discover what of types data can be used as evidence for your product’s claims with PAAB.
3) Digital marketing & communication masterclass
From AI and chatbots to deploying social media campaigns for disease awareness, turn digital innovation into an opportunity, and not a challenge.
4) PAAB Clinic
Collaboratively build several traditional and digital Advertising/Promotional Systems while tackling challenging issues provided from PAAB.
Those who would benefit from the PAAB workshop:
This training is designed for anyone working on healthcare advertising, marketing or communication materials that circulate in the Canadian market. The workshop is designed to support a full range of attendees, from beginners to experienced.
What is the Astellas C3 Prize; Changing Cancer Care challenge?
Astellas is holding its 3rd global contest called the C3 Prize; Changing Cancer Care. Their objective is to provide funding to somebody or to a group with an innovative non-treatment idea intended to improve the lives of cancer patients, caregivers, and their loved ones, especially in low- and middle-income countries.
The winners will receive grants and access to resources to make their life-changing ideas a reality.
This is such a fantastic idea! A win-win for patients and for the innovator! And yes, Astellas is gaining visibility as a results, and that’s perfectly fine. Many consumer products run similar programs (ie. think pink ribbon for breast cancer), and it’s OK for them to gain awareness as a result as well.
Astellas promotion of C3 Prize Challenge on Facebook:
Astellas is sponsoring Facebook ads to promote their C3 Prize challenge to a long list of countries. We can tell this now because Facebook recently changed the way that we can view ads of a particular Facebook page. You can now see which country the ad is being targeted to. The image below shows only a small fraction of the countries where the Astellas Facebook page is promoting the C3 Prize ads.
Here are the C3 Prize ads that one can find on the Astellas Facebook page (confirmed from July 10th to 15th). There is a mixture of still images and videos, and all have the button “Apply now”;
Unfortunately, these sponsored Facebook posts have not done as well as most of the other posts by Astellas from May 14 to July 14 2018, in terms of engagement (Source: Social Insider). This was probably expected though for the following reason. Astellas posts a lot of interesting information on their Facebook page. Their posts which are targeted to a larger, mainstream audience get more shares and more likes. It is difficult for posts, such as the C3 Prize challenge, which are targeted to a much narrower audience, to compete with the mainstream posts. With the C3 Prize challenge posts, Astellas is reaching out to a very narrow group of healthcare entrepreneurs who are looking to get their innovative cancer care idea off the ground. There are only a handful of those people around on Facebook.
Astellas promotion of C3 Prize Challenge on LinkedIn:
Despite the challenge in reaching entrepreneurs on Facebook, there is no shortage of business-minded, motivated entrepreneurs on LinkedIn. As such, it is not surprising to see that the Astellas C3 Prize challenge posts on Linked are resulting in substantial engagement.
Astellas promotion of C3 Prize Challenge on Twitter:
Several months ago, Twitter announced that we would be able to access a hub of some kind to find ads by particular accounts, but that has not happened yet. As such, I am unable to tell whether Astellas is sponsoring advertisements on Twitter or not. However, there are quite a few posts using the #C3Prize hashtag. Here are a couple of examples below.
Astellas #C3Prize Twitter chat statistics:
Astellas held a Twitter chat on July 12th, at 2pm E.S.T. This is a great way to create a live conversation between stakeholders to create more awareness and generate buzz around a particular hashtag.
Astellas cleverly created an image to attach to some of its first Twitter post during the Twitter chat itself, as it outlined the process and guidelines of the chat. They made certain that chat participants would know that their ideas were not going to be evaluated during the chat and that anybody seeking information about medical treatments should discuss with their physician.
Here are some data a little over 24 hours AFTER the Twitter chat:
As would be expected, there was a large increase in the usage of the #C3Prize hashtag during the Twitter chat, and the usage of the hashtag almost immediately went back to base level afterwards.
The majority of the hashtag users were male both before and after the Twitter chat.
Almost half of the tweets posted with the #C3Prize hashtag were initiated on desktop, with the rest on some kind of mobile app. This means that Astellas needs to prepare digital content that will be well viewed on both desktop and mobile devices.
Approximately 2/3 of the posts with the #C3Prize hashtag were retweets of other posts that contained the hashtag. Almost 1/3 of the posts were original posts. Original posts during a Twitter chat are key because these are the ones that will generate replies and retweets.
More than half of the tweets with the #C3Prize hashtag were positive in nature, and only around 10% were negative. The overall sentiment score is calculated based on positive ad negative data. One must be careful when looking at the negative data because it only takes one negative word in a tweet to label that tweet negative. For example, one tweet during the chat had the word “unhealthy”, but the content of the tweet was not negative at all. It was part of the discussion which was about cancer in less fortunate areas. Nonetheless, it is quite possible that the Keyhole algorithm just read that one word and then labeled it as a negative tweet as a result.
Here is some complimentary data about the Twitter chat from Socialert:
The majority of the tweets with the #C3Prize hashtag came from the US with a few countries, including Canada, showing up as secondary users.
The profile keywords give you an idea of the type of people who used the #C3Prize hashtag, as these are words that appear in the participants’ Twitter profile. Seeing the words “cancer”, “health”, “care” and “palliative” indicate that many of the participants describe themselves or their job with these words, therefore are vested in healthcare and may be influencers.
The top 3 hashtags used during and slightly after the Astellas #C3Prize Twitter chat were #C3Prize (naturally!!), #CancerCare and #Cancer.
The hashtag #CancerCare was also used by Astellas in their tweets about the C3 Prize. The #CancerCare hashtag appears to be more commonly used. Astellas must be pleased that their company name was one of the most prominent keywords in tweets containing the hashtag #CancerCare over the past 10 days (source Keyhole, July 4 to July 14 2018).
Based on this review, it seems as though the #C3Prize Twitter chat was fairly successful. Although the hashtag didn’t trend, one has to remember that this was not meant to be a mainstream Twitter chat. This was a Twitter chat targeted to a handful of people who are entrepreneurs in the healthcare field, and who are searching for funding to make their innovative idea come to fruition.
We can learn from Astellas about using social media to promote a challenge:
Your target audience for the challenge will determine your success on various social media platforms. Entrepreneurs can be found more easily on LinkedIn compared to Facebook and Twitter.
A Twitter chat which includes a few influential participants can generate a fair amount of noise during a peak period.
Setting up clear Twitter chat guidelines and promoting them ahead of the chat can reduce confusion.
Combining your customized hashtag with an associated, more commonly used hashtag to generate greater awareness to a larger audience.
Good luck to all the #C3Prize participants and best wishes to Astellas in choosing their winners amongst all the innovative ideas that they will certainly receive.
At the bottom of this post, you will find screenshots of 44 page Facebook covers from either global pharmaceutical organizations or pharma companies in Canada. The screenshots were taken in June 2018, and a few of them have already been updated as of early July 2018. The pharmaceutical Facebook covers are in alphabetical order of the pharma company’s name.
Pharmaceutical companies on Facebook
Pharma companies are increasingly communicating and sharing on social media, including Facebook. Although there are some Canadian pharmaceutical subsidiaries that manage their own social media profiles, the majority still rely on their global headquarters to do the communications.
Most of the pharmaceutical Facebook pages that I have seen focus either on non-branded corporate activities, careers within the organization, news about their research or events that are hosted by either themselves or a related medical association.
Pharmaceutical Facebook Page Covers
Pharmaceutical companies on Facebook have the opportunity to visually highlight their page’s objective with their Facebook cover image, slide show or video. They can also change their Facebook cover page image anytime.
The majority of the pharmaceutical Facebook covers that I found consist of still images, with a couple showcasing videos, a .gif file, or a slideshow. Their call-to-action buttons vary from ‘Learn more’, ‘Watch video’, ‘Contact us’, ‘Call us’, to ‘Sign up’.
Many of these pharma Facebook page covers depict happy people while others show happy or serious scientific researchers. They are well done and pleasing to the eye, but they really don’t differentiate themselves from one another.
Pharmaceutical Facebook Page Covers That Stand Out
A few of the covers are innovative and self-explanatory such as the Allergan eye image, the Abbvie ‘gives back’ images, and the Novo Nordisk‘s compilation of old photos including that of an old insulin bottle to celebrate their 95th year in diabetes research. The cover by Pfizer global is a video which captures one’s attention as it presents its employees as regular people with personal lives and then show them dedicated to a common goal as Pfizer colleagues.
Most of the pharma Facebook covers don’t have any messages on them, but a few highlight their specialty, making it absolutely clear what they are all about, in particular the Leo Pharma, Novartis Cancer and Novo Nordisk covers.
The 1st image of the Abbott Facebook page cover was taken in June 2018 whereas the 2nd image was taken in early July 2018. An image of the July 2018 Abbott Facebook page cover taken from a mobile device is also included to show you how the covers look differently depending on the platform that the visitor is using.
Below is what the Abbott Facebook page cover looks like on a mobile device. Notice that the image size on mobile is not in the same ratio as it is on desktop. You tend to lose a bit of the left side of the image on mobile, so whenever possible, give more weight to the right side of your image and leave a little space on the left so that you don’t lose part of your image or text as Abbott did on mobile.
This is an interesting situation. The Apotex Facebook page was created on June 16, 2015. Posts were published on this page until July 2, 2015. Usually, I would assume that the page was started by a person or group that wants to discuss Apotex or its brand. This happens all the time and it is usually by people who are quite passionate about their stance on the company or brand, either positive or negative. However, if you look at some of the posts on the Apotex Facebook page, they appear to come from either the corporation itself or a representing agency. Consumers do not typically write posts in this manner.
Obviously, the page has been abandoned. If Apotex did have anything to do with this page, they may want to consider making it invisible to the public or deleting it completely.
By including a clear and simple message on their Facebook cover page, Leo Pharma lets their visitors know exactly what their company is all about. As far as I can tell, this is well within Canadian direct-to-consumer advertising regulations as well since none of the posts that I reviewed include information about a specific product. Remember that in Canada, we can only promote product name, price and quantity to consumers. Combining a product name with an indication goes against the guidelines. The posts on Leo Pharma’s Facebook page focus on corporate activities and partnerships with investors. Well done, Leo Pharma!
The Pfizer Facebook page cover is worth watching. The message is clear that all of their employees are different, have their own unique personal lives, but when they go to work, they are all dedicated to one common goal. Their ads (targeted to the U.S. audience) support this message as well.
Update June 27 2018, 12:23 pm: Pfizer Canada sent me an email to inform me that they have read my blog post and addressed the issue immediately. They have removed the ads from the EpiPen Canada Facebook page. I personally thank Pfizer Canada for taking my recommendation seriously and congratulate them for taking such speedy action.
One of my children needs to carry an EpiPen Junior all the time, so naturally, I follow the EpiPen Canada Facebook page. I have always been impressed with the quality of their posts .
Despite my personal interest in the brand, I am a marketer at heart and I like checking out the ads on certain Facebook pages. But this time, I came across an unusual situation.
Under the “Ads” tab of the EpiPen Canada Facebook page were ads for rheumatoid arthritis options and Pristiq, a prescription drug indicated for the symptomatic relief of major depressive disorder. For those who aren’t familiar with EpiPen, it is an epinephrine autoinjector for serious allergies. There is no obvious relation between the EpiPen Facebook page or the two ads.
Imagine the confusion that people who see these ads on their Facebook timeline when they see that the ads come from the EpiPen Canada Facebook page yet are completely unrelated.
With such a strong focus on transparency when it comes to advertising, it seems odd to see the EpiPen Canada Facebook page advertise for other brands which belong to its parent company, Pfizer.
Where should these ads appear on Facebook?
Pfizer Canada, the distributor of EpiPen in Canada, has an active Facebook page. It would have been more appropriate to run these advertisements from the Pfizer Canada Facebook page. At the time when I saw the ads on the EpiPen Canada Facebook page, the Pfizer Canada Facebook page did not have any ads listed.
Why would EpiPen promote Rheumatoid Arthritis options and Pristiq?
Rationale 1: Skirting regulatory guidelines?
Initially, I thought perhaps the company was trying to separate its ads from other related ads which may have been perceived as going against the direct-to-consumer (DTC) advertisement regulations by Health Canada. For example, in Canada, pharmaceutical DTC can ONLY refer to aproduct’s name, price and quantity. The moment you mention a disease as part of the ad, any mention of the product name must be removed. It’s one or the other, never both.
If a particular Facebook page were to advertise about a disease state in one ad, and at the same time advertise about the related product, that would probably get the company in trouble. But this was NOT the case, since Pfizer Canada had no ads listed at all. Phewfff!
Rationale 2: Human error?
Another rationale for this mix-and-match of ads on a Facebook page is that somebody probably just made a mistake, either by not realizing that the ads should have been on the Pfizer Canada Facebook page, or simply did not realize that they were placing the ads on the EpiPen Canada Facebook page
This would be particularly plausible if the agency handling the brands’ online and social advertising managed both the corporate social media as well as the social media for EpiPen. But frankly, it seems to me that this could inadvertently happen for one ad, but for two? Hmmm … probably not.
Rational 3: Corporate politics?
Pfizer is a very large company. Perhaps there was a lot of red tape to go through to get approval to place these ads under the overarching Pfizer Canada Facebook page so a decision was made to get the ads out quickly and to just go piggy-back off the EpiPen Facebook page. As marketers in any industry, we all need to be a bit creative sometimes.
Who knows why this happened. Perhaps I my guesses didn’t even come close. Whatever the reason, I honestly do not believe that any ill intentions were involved. Nonetheless, those ads should not remain under the EpiPen umbrella.
What should be done about these unrelated Facebook ads?
Although it is not the end of the world, having one brand advertise for a totally unrelated brand or disease state looks unprofessional. It may also be perceived as unethical because it lacks transparency and it could be confusing to patients who see the ads on their Facebook timeline.
Just my two cents, but Pfizer Canada may want to consider deleting the unrelated ads from the EpiPen Canada Facebook page and reinstating them under the Pfizer Canada Facebook page, or creating separate, new Facebook pages that are specific for the individual ads.
What other interesting Facebook advertising scenarios have you come across?
Accu-Chek is currently running Facebook ads, one in English and one in French, to raise awareness of the fact that there is a higher prevalence rate of diabetes among Canada’s First Nations peoples. Although I do not have access to the targeting specs for the ads, based on the types of comments the ad is receiving, it appears as though the general Canadian public has been seeing the ads on their timeline.
I respect Accu-Chek for sponsoring this Facebook ad. We need to see more ads like this, which may help communities within Canada who might need a little extra hand.
Something that would have been appreciated by the First Nations peoples would have been an ad in one of their more popular dialects. Something for Accu-Check to consider next time.
If your inbox looks anything like mine, you have received quite a few notifications over the past few weeks about companies who have updated their guidelines to improve your privacy. These updates are in response to the GDPR (General Data Protection Regulation), the European Union’s new data privacy law which came into effect as of May 5 2018.
Companies that collect, store or analyze information on EU residents must now be more transparent about the data they have and who they share it with.
If an EU resident asks a company to delete his or her data, to send a copy of his or her data, or agrees for a company to collect his or her data but not use it in specific circumstances, the company must comply.
If the GDPR is specific for EU residents, why are companies based in other countries required to comply as well?
If a company, or online service regardless of where it is located, has any data on an EU resident, they must comply. Basically, the GDPR has become a global standard. This is actually good news for non-EU residents as they now share the same rights as EU residents, except that they have no legal right to complain if any issue related to this topic arises.
Canada Privacy Guidance Online
On May 24th, the day before the GDPR became applicable, the Canadian Privacy Commissioner issued 2 new Canadian privacy guidance documents to steer webpage owners in the right direction when it comes to content challenges on the internet. Here is a summary of the 2 Canadian privacy guidance documents. The information is copied directly from the documents because I did not want to use incorrect wording that would change the meaning of the guidance principles, but please keep in mind that I have only included excerpts that I deemed most important. If you are a Canadian webpage owner that collects information on its viewers, then I strongly advise that you read both Canadian privacy guidance documents in their entirety.
Emphasizing certain key elements in privacy information and explaining them in a user friendly way
2. Allow individuals to control the level of detail they get and when
Information must be provided to individuals in manageable and easily-accessible ways (potentially including layers) and individuals should be able to control how much more detail they wish to obtain, and when.
3. Providing people with clear options to say ‘yes’ or ‘no’
4. Be innovative and creative
Organizations should design and/or adopt innovative consent processes that can be implemented just-in-time, are specific to the context, and are appropriate to the type of interface used.
5. Consider the consumers’ perspective
Consent is only valid where the individual can understand that to which they are consenting.
6. Make consent a dynamic and ongoing process
Informed consent is an ongoing process that changes as circumstances change; organizations should not rely on a static moment in time but rather treat consent as a dynamic and interactive process.
Organizations should also consider periodically reminding individuals about their privacy options and inviting them to review these.
Organizations should periodically audit their information management practices to ensure that personal information continues to be handled in the way described to individuals.
7. Being accountable and standing ready to demonstrate compliance
Organizations, when asked, should be in a position to demonstrate compliance, and in particular that the consent process they have implemented is sufficiently understandable from the general perspective of their target audience(s) as to allow for valid and meaningful consent.
Collection, use or disclosure that is otherwise unlawful.
Profiling or categorization that leads to unfair, unethical or discriminatory treatment contrary to human rights law.
Collection, use or disclosure for purposes that are known or likely to cause significant harm to the individual.
Publishing personal information with the intended purpose of charging individuals for its removal.
Requiring passwords to social media accounts for the purpose of employee screening
Surveillance by an organization through audio or video functionality of the individual’s own device.
Pharma companies sometimes hold very personal information that could allow for a person’s identity and perhaps even associate that person with various health issues. Since the social media profiles and blogs by pharmaceutical companies are often managed by the global office yet reach website users from around the world, it makes sense that the majority of the pharmaceutical companies probably updated their privacy policies to better reflect the requirements of the GDPR as well because they certainly get visitors to their sites from various European countries (amongst many other countries).
OK, so this response wasn’t earth shattering, but hey, they took the time to respond back and their response is definitely accurate and to the point.
Privacy disclaimer and community guidelines for Novo Nordisk’s social media accounts
We welcome and encourage your participation and engagement. When you engage with us on social media, you also agree to follow our disclaimer and community guidelines that explain how we use data and the restrictions of our social media pages.
Thank you for your understanding and for ensuring that your comments fit within these guidelines. While we reserve the right to remove any posting at its sole discretion, we are working to foster openness and dialogue and will therefore only remove comments that violate these guidelines.
Privacy disclaimer 1. The information we collect
We collect information for statistically purposes that can help us improve our communication. When you follow us on social media or engage in our content (via likes, shares, comments etc.) we automatically collect this information and use it to inform us if our content is relevant, where our visitors come from, what they look for and act on, and where the most time is spent. The information we gather about impressions and engagement does not include any personally identifiable information. 2. Collection of sensitive data
We do not collect or retain sensitive personal data relating to your health, ethnic origin, religious beliefs or political conviction etc. on social media. In the rare case where we do seek to collect other sensitive data we will do so in strict compliance with local data privacy law.
6. Information provided ”as is”
The information on our social media sites is provided “as is” and we make no representations or warranties, expressed or implied, including but not limited to the implied warranties of merchantability, fitness for a particular purpose or noninfringement.
We make no representations or warranties of any kind as to the completeness, accuracy, timeliness, availability, functionality and compliance with applicable laws.
By following our accounts you accept the risk that the information may be incomplete or inaccurate or may not meet your needs or requirements.
Community guidelines 1. Product mentions and medical advice
Due to the nature of our industry, we cannot talk about certain topics with you online. If that is the case, we will let you know and provide others means in which to connect.
Our social media accounts are not intended for discussions about products made by Novo Nordisk A/S including the reporting of side effects associated with the use of prescription drugs.
Any questions or comments specific to products should be made to your healthcare professional.
Social media is not a place for us to provide healthcare advice. If you have questions about your health or the medicine you take, your doctor or health care provider is the person to ask. If you have issues with our medicines (an adverse event), or if you have a product inquiry or complaint, please contact Novo Nordisk’s office in the country you live.
For other comments or feedback please contact us via content (messages) on our accounts that is managed by colleagues in Novo Nordisk in Denmark, on behalf of our colleagues across the organisation.
2. Tone of voice
We welcome comments and questions and try to join the conversation whenever possible. However, we may remove any comments that: (1) are off-topic; (2) are inappropriate, vulgar or abusive; (3) are intended to spam; (4) reference a product; (5) solicit or offer medical advice; or (6) otherwise violates our community guidelines.
3. Information purposes
The content posted on our accounts is presented solely for informational purposes. The accounts do not provide you with advice or recommendation of any kind and should not be relied on as the basis for any decision or action. You are advised to consult professional advisors in the appropriate field with respect to the applicability of any particular aspect of the contents. In particular, nothing being posted constitutes an invitation or offer to invest or deal in Novo Nordisk securities.
Further, our accounts provide selected information of diseases and their treatment. Such information is not intended as medical advice and cannot substitute for the advice of a health care professional. If you have or suspect having any health problems, you should consult your general practitioner or other qualified health provider.
5. Replies, comments and direct messages
We welcome feedback and ideas from all our followers, and encourage you to join the conversation where possible. We will read all replies, comments and messages and ensure that any emerging themes or helpful suggestions are passed to the relevant people in our organisation.
Thanks for reading and for connecting with us.
*** Leave me a comment below to let me know if this information was helpful and if you like seeing examples of privacy policies and community guidelines by pharma and healthcare organizations.