Is PAAB review required for chatbots?

88341455_sMarketers 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.

-Patrick Massad, Deputy Commissioner, PAAB.

For more on how PAAB reviews chatbots, download the PAAB training document Artificial Intelligence (AI) for Canadian: Pharma: Opportunity or risk?

Want to learn even more than what’s in the training document, then join us at the upcoming PAAB workshop: Download the agenda and register now!

Workshop dates:

November 20, Montreal

November 22, Toronto

Early Bird Special:
Book by September 28, 2018 and save $50

 

Marketing 4 Health Inc. is pleased to help raise awareness for the PAAB workshop.  We hope to see you there!

44 Pharma Facebook Covers; Global and Canada

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.

Take a look and let us know what you think.

 

Abbott:

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.

FB cover - Abbott

FB cover - Abbott - 2017 07

 

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.

Screenshot_2018-07-07-10-00-49.png

 

Abbvie Careers:

The 1st image of the Abbvie Careers Facebook page cover was taken in June 2018 whereas the 2nd image was taken in early July 2018.

FB cover - Abbvie careers

FB cover - Abbvie Careers - 2017 07

 

Abbvie Global:

The 1st image of the Abbvie Global Facebook page cover was taken in June 2018 whereas the 2nd image was taken in early July 2018.

FB cover - Abbvie

FB cover - Abbvie - 2017 07.png

 

Alcon:

FB cover - Alcon

 

Allergan:

FB cover - Allergan

 

Apotex:

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.

FB cover - Apotex - now defunct page - looks official

 

Astellas:

FB cover - Astellas

 

Bausch & Lomb (changed from Bausch & Lomb Canada in 2015):

 

 

 

Bayer:

FB cover - Bayer

 

Biogen:

FB cover - Biogen

 

Bristol-Myers Squibb:

FB cover - BMS

 

Celgene:

FB cover - Celgee

 

Eli Lilly:

FB cover - Eli Lilly

 

Genentech:

FB cover - Genentech

 

Gilead Sciences:

FB cover - Gilead Sciences

 

GSK:

The 1st image of the GSK Facebook page cover was taken in June 2018 whereas the video below it was taken in early July 2018.

FB cover - GSK

 

Ipsen:

FB cover - Ipsen

 

Johnson & Johnson Careers:

FB cover - J&J careers

 

Johnson & Johnson:

The Johnson & Johnson Facebook cover page is actually a .gif file where all you can see moving is the baby rattle.  The rest of the image remains still.

FB cover - J&J

 

Leo Pharma Canada:

FB cover - Leo Pharma Canada

 

Leo Pharma:

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!

FB cover - Leo Pharma

 

Merck Careers:

FB cover - Merck careers

 

Merck for Mothers:

FB cover - Merck for Mothers

 

Merck:

FB cover - Merck

 

Novartis Cancer:

FB cover - Novartis Cancer

 

Novartis:

FB cover - Novartis

 

Novo Nordisk Canada:

FB cover - Novo Nordisk Canada - no posts just ads

 

Novo Nordisk:

FB cover - Novo Nordisk

 

Pfizer Canada:

FB cover - Pfizer Canada

 

Pfizer:

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.

 

 

 

Pharmascience:

FB cover - Pharmascience - Cdn page

 

Regeneron:

FB cover - Regeneron

 

Roche Careers:

The image and message on the Roche Careers Facebook page cover are well crafted to attract potential team players.

FB cover - Roche careers

 

Sandoz Global, A Novartis Division:

FB cover - Sandoz - 2017 07

 

Sanofi:

FB cover - Sanofi France - no posts

 

Sanofi US:

FB cover - Sanofi US

 

Sanofi Genzyme:

FB cover - Sanofi Genzyme - 2017 07

 

Sanofi Pasteur Centenary:

There are not many posts on this page, but the concept of celebrating their centenary on Facebook is fun.

FB cover - Sanofi Pasteur Centenary.png

 

Solvay:

FB cover - Solvay

 

Takeda:

FB cover - Takeda Oncology

 

I plan on updating this blog post from time to time.  Are there other Facebook page covers that you would like to see added to this list?

Facebook and Twitter to Make Ads Visible to the Public – Impact on Healthcare and Pharma

Facebook, Instagram, Messenger and Twitter will soon be making ads visible to anybody who wants to see them.  Yes, anybody!  Patients, healthcare providers, competitors and advertising regulatory bodies.

This new ad transparency on social media is a result of the Russian ads that were placed on social media during the last American election. Tisk tisk!

Up until now, you saw ads on social media that were targeted to you based on the advertisers’ filters when placing the ad.  But very soon, you will be able to actively search and find ads by specific users with just a click of a button.  This is both exciting and unnerving for advertisers in all industries, including the pharmaceutical and healthcare industries.

What are the social networks doing to make advertising more transparent?

Facebook, Messenger and Instagram will be starting this process near the end of 2017 in Canada first and then will roll out to the United States by July 2018.  There will be a “View Ads” button to click on a Page to view the ads that the Page is currently running.  As such, all ads will need to be associated with a Page

Twitter will work a bit differently.  There will be an Advertising Transparency Center that will become public in the coming weeks.  From here, you will have access to the following information:

  • All ads that are currently running on Twitter
  • Amount of time that the ads have been running
  • Ad creative
  • Ads targeted to you, as well as personalized information on which ads you are eligible to receive based on targeting

Viewers of the ads on any of these platforms will be able to give immediate feedback and report ads.

So how will this impact social media advertisers within the pharmaceutical and healthcare industries?

    • Transparency means that people can see everything, so expect exactly that!  Expect competitors to come snooping around more often to see what you are advertising.  As you will probably use this as an opportunity to do more thorough competitive advertising reviews as well, right?

 

    • In the past, we could only estimate how much a competitor was advertising on social media.  But now we will have access to all the details.  If one realizes that competitors are way more active than what was previously thought, it is possible that we will see a surge in advertising by others, especially if their strategic objective is to target the users of a specific competitive brand.  However, I don’t anticipate this to happen for the Canadian pharmaceutical industry because of the restrictions in direct-to-consumer advertising.  In Canada, it will really still just be the market leaders who will benefit the most from these types of ads.  But in the United States, it is a possibility.

 

    • Expect more feedback and possibly reporting of your ads by either consumers or competitors.  Hopefully you will get positive feedback, but beware, because even your test ads will be visible now.  In speaking with Ad Standards (the organization that reviews Canadian consumer advertising for prescription drugs, OTC, medical devices, natural health products and very soon vaccines as well), they do not expect any significant changes to the number or type of complaints that they usually receive either from consumers or competitors.  Personally, I’m not so sure about that.  Some competitors are fierce about trying to stop advertising by others, but we all know that that usually ends up biting them right back in the you-know-what.  But we all know that some will absolutely be taking that chance anyways.

 

    • Speaking of test ads, we may find that advertisers test for shorter periods of time in order to limit the window of opportunity of competitors seeing their draft ads.  We all know that we need to test our ads, but who wants to do that openly?  We won’t have a choice, but I cannot imagine that many of us will be comfortable with that.

 

These are nothing more than guesses, so it will be interesting to review the impact a year from now to see which of these turned out to be correct and which did not.

Competitive review of social media ads:

Call me crazy, but I love finding healthcare-related ads and analyzing their creative and copy, and now I’ll be able to see a bit of their targeting features as well.  Woohoo!!!  I am looking forward to finding new pharmaceutical and healthcare ads on social media and sharing some of them with you so that you can share your thoughts on them.  Below, you will find a few that I spotted during the past few weeks on Facebook.  Enjoy!

If you would like a thorough social media advertising review for a particular therapeutic area or specific competitors, then please contact me at nat@marketing4health.net .  Truth be told, it would be my absolute pleasure to be your eyes and ears on social media!

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280 Twitter Characters and Canadian Pharma

wersm-twitter-280-characters-657x360

Image from wersm.com

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.

For a greater analysis of the impact of a longer tweet in the American pharmaceutical industry, please check out Andy Grojean’s article from 2016 “Beyond 140: How Twitter’s 10K Character Limit Could Change the Game for Pharma”.

OTC brands in Canada will benefit

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.