Pharmacovigilance
The industry should take a proactive approach rather than just a reactive approach to social media.
*Pharma companies should implement policies and/or procedures on social media platforms to ensure that they meet their pharmacovigilance responsibilities.
*If the company (or an individual or third party on its behalf) becomes aware of an adverse event associated with a company product, it must be reported.
*It is recommended that comments underneath advertising/ communications and direct messages to company owned or sponsored social media accounts are monitored for pharmacovigilance; alternatively, they can be restricted on certain social media channels.
Transparency
A pharma company’s involvement in anything social media should be clear and prominent so the viewer/reader knows from the outset. This also includes when any third party is acting on the company’s behalf or carrying out such activities such as: Sponsorship funded videos or podcasts. There should be a disclaimer of the company’s involvement at the beginning, not at the end, otherwise there will be a breach of code.
Third Party Responsibility
A pharma company is responsible for all material disseminated/ activities carried out by any of its social media channels, or those on which its personnel post on. Therefore, a pharma company is responsible for all Third parties who carry out activities on the company’s behalf, even if those third parties act contrary to the instructions they’ve been given by the pharma company. Even If the contract has ended the agency is still considered a third party.
Social Media Influencers
Social media influencers must be extremely well briefed about the requirements of the code. Companies will be held accountable for actions of contracted parties, even if they act contrary to the instructions given to them. Therefore, a pharma company must exercise caution when working with social media influencers.
Responsibility of Employees
Pharma companies should assume that the Code would apply to all work-related, personal social media posts by their employees on platforms inside the UK, within the Code’s jurisdiction unless for very clear reasons, it could be shown otherwise
Links, Tagging, Hashtags
Any material associated with a social media post, including the link within the post is regarded as being part of the post. How the link is structured, and what words the link contains will be considered in the assessment of what is promotional. This includes a combination of hashtags used. Account(s) mentioned
should be appropriate and care must be taken to ensure they are mentioned respectfully and only brought into the relevant discussions. Companies must ensure that linked content is appropriate and does not promote a POM to the public. It is the company’s responsibility to ensure the link in the company post is both appropriately named and clear whether the link is to the pharma company material/ website or non-company material/ website.
Posting/Sharing/ Re-Sharing
Companies must ensure that shared/reshared content is in line with the ABPI code and is approved and certified if necessary. Anything which alerts a person’s connections to the content will be seen as a type of sharing. Engaging with a post e.g., liking the post on LinkedIn, might alert one’s connection to the content. Therefore, liking content on LinkedIn is considered to be a type of sharing/ resharing. This will only apply to employees/ third parties contracted to the pharmaceutical company or the company itself.
The guidance strongly advises that the Company provide training to their employees toensure compliance with the Code’s rules on social media.
Content Posted from Other Companies Which Relates to Your Company/Your Products
A pharma company is responsible for its own employees and cannot be responsible for what another pharma company/ pharma company employee does. You will not be in breach of the Codes if another company posts/ mentions your company or your products. What will bring your company into a breach of the codes is if a UK based employee likes or comments on that content. Then it will be seen as promotional and there will be a breach.
Advertisements and Clinical Trial Recruitment
Clinical trial recruitment must be targeted at appropriate demographic and must not raise unfounded hopes of a successful treatment. It must avoid referring to specific products and include a description that supports appropriate people/ patients in the disease areas to find out more about the clinical trial. A pharmaceutical company that wants to recruit over social media must consider all of the other applicable codes, laws and regulations including the requirements of the Health Research Authority (HRA).