It’s been a long time coming, but the draft social media guidance released this week by the US regulator goes some way to addressing the needs of marketers anxious to engage with their customers and still fulfil regulatory requirements.
There has been understandable nervousness about the potential pitfalls of jumping into the social space which has meant that pharma has tended to lag behind other industries in fully engaging with the opportunities offered by social (or ‘tools and technologies that allow for real-time communications and interactions’ as the FDA snappily puts it).
The Guidance does provide some clarity on exactly where responsibilities lie – essentially product communications using platforms that are subject to ‘substantive influence by firms that market the product’.
Thus any communication appearing on sites owned, controlled, created, influenced or operated by or on behalf of the firm, is the responsibility of that firm.
This responsibility is also extended to third party sites, if the firm has any influence or control over the content of this site.
Likewise firms are responsible for any content appearing anywhere that has been generated by an employee or agent acting on behalf of the firm to promote a firm’s product.
It feels all very reasonable and straight forward, but as always the devil is in the detail. Particularly when it’s your site, your customers, your facebook forum and your responsibility .
The key thing to acknowledge for anyone moving into this arena is that this needs commitment – it’s not a case of setting up and letting it run. Social media is dynamic, fast-moving and needs constant monitoring. And you need to know that there’s a safety net in place that protects you against potentially non-compliant posts even if they arrive at 2.00 am on a Christmas morning.
So if you’re still teetering on the brink, where to start? Well, by listening. By monitoring what’s already being said about your brand and those of your competitors, on all of the channels that you’re not in control of. Sounds obvious, but at a recent event we attended, less than a third of the audience had got active social media listening in place.
We’re working with more and more companies who are beginning to really engage with their customers, and are now able to see the value of that engagement in the context of the rest on their promotional activity. It really is worth the bother, especially now as the ‘risks’ are a little clearer. If you want to chat through how you might take the next steps, do give us a call.
