Over the past 20+ years, he has saved me from getting into regulatory trouble on multiple occasions during my brand management days, and once I went off on my own, he still took the time to discuss topics for my blog and even connected me with various people who might lead to business opportunities. In fact, Ray brought me in for my very first pharma social media training session to train the PAAB reviewers. That was when social media was still in its infancy. One of the highlights of my career was back in 2009 when Ray invited me to sit with him and others on a speaker panel focused on social media & pharma. I felt so intimidated but Ray always showed his confidence in me.
I, as well as many other Canadian pharmaceutical marketers, learned a lot from Ray, both from a regulatory and a leadership perspective. Thank you, Ray, for your kindness, generosity and support throughout all these years. Best wishes on your well-deserved retirement.
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.
Twitter recently announced that it is testing 280 characters per tweet. That is double what they currently allow. What does this increase in tweeting space mean for the Canadian pharmaceutical industry?
Direct to consumer advertising of prescription products in Canada
In Canada, prescription drugs can only be promoted to healthcare professionals. Direct to consumer (DTC) advertising can only mention a product’s name, quantity and price. The product name cannot be linked to a disease state or promotional messages as this would then be considered advertising, and that would be a problem because it goes against the Pharmaceutical Advertising Advisory Board (PAAB) guidelines.
Ray Chepesiuk, the Commissioner of PAAB, had this to say about the new 280 characters:
“If you don’t have the ability to close off the audience so that only healthcare professionals see your tweets, then it’s still a problem because you cannot control your target audience. It’s the same problem with Facebook which has always allowed a lot more characters. You must ensure that only certain groups have access to your promotional information. Once you can isolate an audience, then you must follow section 6 of the PAAB code.”
Just remember that even though the maximum characters in a tweet may be changing, the drug advertising rules are not.
Institutional messages and PR by Canadian pharmaceutical companies
However, if a Canadian pharmaceutical company wants to send information about their organization (ie. charitable donations, community programs, relief missions to send drugs to other countries, a patient drug program, etc…) and still include the product name, it can be done within the guidelines. As long as you do not link therapeutic use and brand, as that would exceed name, price and quantity, you should be OK.
Hashtags make it easier to find your tweet
Another benefit is that having space for additional hashtags could help make your post easier to find. But make sure that post is not considered advertising, and you cannot be sneaky and include promotional hashtags because then you’ll be crossing the line.
Things will be a bit different for the US pharmaceutical industry
The new 280 characters could be a little more exciting for US pharmaceutical advertisers. There, online DTC advertising can reference their brief fair balance summary to somewhere else (ie. in an ad that they published in a magazine or elsewhere). In the US, they can probably use the extra characters to get more message in about their drug and meet their fair balance and legal obligations. This is not an option in Canada.
As for DTC advertising of over-the-counter (OTC) products in Canada, there is certainly much greater latitude in the way that they can be promoted. Therefore, the OTC companies are probably pleased about the extra character allocation, because they will be able to be more creative in their use of their extra space.
Overall, the increase in Twitter characters will be slightly beneficial to the Canadian pharmaceutical industry but presents greater opportunities for OTC brands and corporate messages.
What are your thoughts on this? And are you one of the lucky people who already has access to the 280 characters on Twitter? I don’t, not yet anyway. I love reading your comments, so please share what is on your mind.