Digital marketing masterclass for branded
materialsSpeaker: Dannie Newman, Reviewer, PAAB
Agenda
• Understand how target audience and product schedules intersect to determine the regulations relevant to advertising (consumers)
• Creating digital tools: What do you need to know and how to link assets in a compliant manner
• Work on cases to cement your understanding of regulations relating to SEO and SEM
Identify your audience
Consumers: Messaging directed to the general
public. Readily accessible by individuals who have not been prescribed the product.
Patients: Messaging directed to individuals
prescribed that product OR messaging in a tool intended for use by HCPs only during counseling.
Healthcare professional: Messaging directed to
licensed members of the professions of medicine, dentistry, naturopathy, nursing, pharmacy and related health disciplines and institutions.
Communicating with Consumers
Consumer Advertising or Consumer Information?
What is Drug Advertising?
Definition in section 2 of the Food & Drugs Act:
“Any representation by any means whatever for the purpose of promoting directly or indirectly the sale or disposal of any food, drug, cosmetic or device”
Still unsure?
See the Health Canada policy document:
“Distinction Between Advertising and Other Activities”
Can be found on the Health Canada and PAAB website.
Distinction Between Advertising andOther Activities:
• What is the context in which the message is disseminated ?
• Who are the primary and secondary audiences ?
• Who delivers the message (the provider) ?
• Who sponsors the message and how ?
• What influence does the drug manufacturer have on the message content ?
• What is the content of the message ?
• With what frequency is the message delivered ?
Breaking down the 7 questions.
1. Content /creation factors:
What is the content ?
Who sponsors the message and how ?
Extent of drug manufacturer influence over message content ?
2. Distribution/availability factors
Audience ?
Context of dissemination ?
Who delivers ?
Frequency of delivery ?
“No one factor in itself will determine whether or not a particular message is advertising.”
…If uncertain, don’t hesitate to ask PAAB.
We’ll respond to requests for written opinions within 4 days.
Communicating with Consumers
For Consumer Information (non-advertising):
Need to consider the relevant provisions from the “Distinction” Document.
Examples:
Help-seeking Messages
Consumer Brochures
Help-seeking Messages
Consumer Brochure
Consumer Brochure
Communicating with Consumers
For Consumer Advertising:
Need to consider:
product’s federal schedule &
whether disease/condition treated is on schedule A.
Consumer Advertising Regulations
Prescription
drugs
…Some products may have a dual Federal drug schedule
“Choose HerpRexfor the prevention of HPV”
Prescription
Disease Consideration - Schedule A
• Acute alcoholism• Acute anxiety state • Acute infectious respiratory
syndromes • Acute psychotic conditions• Acute, inflammatory and
debilitating arthritis• Addiction, except nicotine
addiction• Appendicitis• Arteriosclerosis• Asthma• Cancer• Congestive heart failure• Convulsions• Dementia• Depression• Diabetes• Gangrene
• Glaucoma• Haematologic bleeding
disorders• Hepatitis• Hypertension• Nausea and vomiting of
pregnancy• Obesity• Rheumatic fever• Septicaemia• Sexually transmitted
diseases• Strangulated hernia• Thrombotic and embolic
disorders• Thyroid disease• Ulcer of the gastro-intestinal
tract
See Health Canada website for list of Schedule A Diseases
DIGITAL ACTIVITIES
eDetail Aids, Apps, Websites, emails, social media
Critical Considerations
forany e-media
type
i) The intent of the message:
Is the intent of the message to promote a drug, disease awareness or a company?
ii) The target audience solicited:
Is the information targeted towards healthcare professionals, patients or the consumer?
iii) The type of drug product:
Does the information pertain to a prescription, non-prescription, vaccine or natural health product?
iv) The nature of the online content:
Does the site allow for dynamic content or is it static (i.e. entirely controlled by the sponsor)?
Key considerations when building a product website
CONTROL OF ACCESS
CONTENT LINKAGES PROMOTION OF WEBSITE
Access Control
• If the content exceeds that which is allowable in a consumer context, there must be a barrier to keep consumers out
• It is the sponsors responsibility to ensure sufficient mechanisms to determine the regulatory category of the person requesting the information online
Creating an acceptable barrier• Registration and/or attestation alone are NOT
sufficient barriers
• Password required for entry (controlled distribution)
• Professional License #
• Arbitrary set of characters selected by manufacturer
• URL of a website which is not indexed
• “keys” which bypass the barrier (controlled distribution)
• CD, webkey, email
• Access through moderator approval (with verification on the front end)
Remember: Landing page is accessible by the consumer
Let’s look at our product website for Jensulin
HCP website landing page
About PAABPharm.ca
Revisions required?
About PAABPharm.ca
Links to page on PAABPharma - approved for DTC use.
Welcome to JENSULIN.ca, your JENSULIN Resource Center
This site contains:- Information on the efficacy of JENSULIN- Guideline Recommendations- Lifestyle tips and programs for your patients- And so much more
Lets get started learning about JESNULIN
Enter your professional licence number here:
*This site is intended for Healthcare Professionals
Content
Websites tend to house large amounts of content
Websites are not typically read in their entirety within a single sitting
Difficult to predict the path users will take through the site.
Challenge:
Effective placement of fair balance (for HCPs)
Solution:
Indication & fair balance on the home page (or beginning of each section containing product claims)
A prominent “Safety Information” menu item visible from any screen on the site
Disclosure of Company
Name
• The name of the pharmaceutical company sponsor should be stated clearly on:
i) Every page of the web-site controlled by the sponsor
ii) On every sponsored web-page of a site with no access control
Homepage
Homepage
About PAABPharm
Safety Information
Linkages
Making Compliant Connections
Linkages
• Principles:
– If you join “advertising” and “non-advertising”, everything becomes “advertising”
– Branded and unbranded disease info • Internet links
• Product Package shot
Linkages• Consider:
• Proximity• Appearance• Sequence• Context
• The sponsor may link to corporate global sites only by linking to the global site home page. The sponsor should not link to the global site product pages/sections.
Linkage
Brand website landing pageUnbranded disease info
Linkage
Unbranded disease info
Colour gradient
Brand visuals
Branded Patient Website
Branded HCP website
HCP direct branded mailerSocial Media
campaignWellness/adherence
reward program
Corporate website
Linkages:
Branded Patient App
Branded patient websiteBranded HCP website
• Branded HCP website to a patient branded website
– Both branded, different audiences
– It is acceptable for the HCP to be exposed to patient material
• Branded patient website to branded HCP website
– Both are branded, but HCP content should not be promoted to patients
Branded patient website
Branded App – Patient support program
• Branded patient app to a patient branded website and vise versa
– This is deemed acceptable and does not change the regulatory status of either platform
Branded patient website
• Patient branded website to corporate website
– Link from branded pre-gate landing page – Not acceptable
– Link from any page post-gate – can link to the homepage
Corporate website
Branded HCP App or HCP website Corporate website
• HCP branded website to corporate website– Link from branded pre-gate landing page – Not acceptable
– Link from any page post-gate – can link to the homepage
• Corporate website to branded HCP app/website– Must link to the landing page – haven’t verified regulatory audience
yet
Branded HCP App
Wellness/adherence reward program
• Branded patient or HCP app linking to an unbranded wellness/adherence reward program
– Unbranded now has to be reviewed in the context of the brand
– Copy which may have been acceptable in the unbranded context may now be challenged
Branded Patient App
Branded HCP App
Social Media campaign
Branded Patient App
• Branded HCP app or patient app linking to social media campaign
– Branded (previously reviewed and approved by PAAB) - OK
– Unbranded disease support group/chat room/blogger
• Sponsors responsibility to ensure that the content meets branded patient regulations
– Violation could affect the acceptability of one or both channels
Promotion of a website
• Search Engine Optimization
• Search Engine Marketing
Search Engine Optimization
(SEO)
Regulations apply to any meta data text provided by the manufacturer (or it’s agent) to a search engine
• Descriptors under control of the sponsor should be submitted for preclearance• Must not exceed consumer advertising
regulations.
• Must not refer to competitor products.
Search Engine Marketing
(SEM)
Meta data requirements are the same as SEO with the addition of sponsor purchased keywords (s.6.5.11)
SEO Keywords
URL Meta description H1 tag Keywords
Jensulin.ca Jensulin.ca, an online resource
designed to provide valuable
information about Jensulin for
healthcare professionals, diabetes
patients and the general public.
Taking Jensulin? Diabetes
Insulin
Glycemic control
Hypoglycemia
Jensulin.ca/
patientlogin
Jensulin patient information Taking Jensulin? Diabetes Patient
Jensulin.ca/
hcplogin
Jensulin information for healthcare
professionals
Jensulin for
healthcare
professionals
Healthcare professional
Diabetes treatment
Jensulin.ca/
talktodoctor
See icebreakers to help you talk to
your doctor about hypoglycemia,
low blood sugar and more.
Help talking to
doctors
Talk to your doctor about
low blood sugar
Jensulin.ca/
realdeal
Learn the dangers of counterfeit
products
Dangers of
counterfeit drugs
Counterfeit
Real Jensulin
Jensulin.ca/
seenontv
See the latest Jensulin commercials
online
As Seen on TV
SEO Keywords
URL Meta description H1 tag Keywords
Jensulin.ca Jensulin.ca, an online resource
designed to provide valuable
information about Jensulin for
healthcare professionals, diabetes
patients and the general public.
Taking Jensulin? Diabetes
Insulin
Glycemic control
Hypoglycemia
Jensulin.ca/
patientlogin
Jensulin patient information Taking Jensulin? Diabetes Patient
Jensulin.ca/
hcplogin
Jensulin information for healthcare
professionals
Jensulin for
healthcare
professionals
Healthcare professional
Diabetes treatment
Jensulin.ca/
talktodoctor
See icebreakers to help you talk to
your doctor about hypoglycemia,
low blood sugar and more.
Help talking to
doctors
Talk to your doctor about
low blood sugar
Jensulin.ca/
realdeal
Learn the dangers of counterfeit
products
Dangers of
counterfeit drugs
Counterfeit
Real Jensulin
Jensulin.ca/
seenontv
See the latest Jensulin commercials
online
As Seen on TV
Subject to consumer regulations; should not identify the therapeutic area
Keywords: Jensulin
Gensulin
Jennsulin
Jensalin
Insulin passad
Diabetes
Injection
HbA1c
Hyperglycemia
Hypoglycemia
Foot care
Blood sugar
Safety profile
Prescribe
Ad related to Jensulin
Jensulin | Jensulin.cawww.Jensulin.ca
Learn about diabetes treatment
ExamplesIf Schedule D and not for the treatment of a schedule A disease:Vaccinator® (11 characters) For prevention of [something bad] (31 characters)Ages 15-55. For risk/benefit info…: (34 characters)http://www.vaccinator.ca
If schedule F:
Arbace®
Learn more about Arbace. http://www.arbace.ca
Summary:
• Composite of the user generated keyword, the metadescriptor, the landing page, and the Uniform Resource Locator (URL) must not exceed consumer advertising regulations.
Questions?
Questions?
Questions?
Virtual Community
CUSTOMER ENGAGEMENT
SHARE INFORMATION
LARGER AUDIENCE
INCREASED RISK
Scope of Online Activities
Apply to all online advertising activities which are:
within the sponsor’s control or influence
and where the intended audience is Canadians.