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Digital Pharma: No breakthrough, but UK’s digital issues out in the open

pharmafile | May 14, 2010 | Feature | Medical Communications Code of Practice, PMCPA, digi, digital, pm society 

The UK’s Code of Practice regulator will produce guidance for pharma on digital marketing, but is reluctant to make formal changes to the existing Code.

That was the message at the PM Society’s Digital Update meeting, held on Wednesday evening in Janssen-Cilag’s High Wycombe offices.

Heather Simmonds is director of the PMCPA, the body that oversees the ABPI’s Code of Practice.

Addressing the meeting she said it would be a priority for the PMCPA to come up with a Q&A document to clarify some of the issues raised by a PM Society working group.

Part of the reason for not adding new ‘digital-specific’ clauses into the Code is the expected dual impact of the European patient information debate and the MHRA’s ongoing review of UK medicines legislation.

Heather was responding to a point raised by the PM Society’s Digital Media Working Group, whose report received its official release at the Digital Update meeting.

The group spent nine months working with UK pharma companies and communications agencies to identify the most common and most challenging queries about the digital environment.

The group is led by Steve Gray, a member of the PM Society Committee who has worked for AstraZeneca and now runs the consultancy Compliance Hub.

“The Code doesn’t, and can’t, address all questions that will come out,” he warned, adding that the consultation had thrown up a huge range subjects, which the group had to work hard to narrow down to just 30 questions.

The group then suggested answers to these questions, with the hope that they would contribute to a framework of formal answers from the PMCPA, which was sent a copy of the report at the end of January.

At the meeting Heather declined to give any guarantees the PMCPA would follow the document’s suggested answers, saying instead: “We will look at a lot of this and we realise how important these issues are.”

Originally the group’s plan was to develop a set of draft clauses for the ABPI Code of Practice, and then submit these to the PMCPA – but, at the regulator’s request, this was not pursued.

User-generated content to search engine optimisation

The working group’s wide-ranging Q&A document took in everything from user-generated content and search engine optimisation, to chat-rooms and banner advertising.

A straw poll at the meeting identified user-generated content, the essence of social media, as the issue that most attendees wanted to know more about when it comes to what UK pharma is allowed to do.

The working group question on the issue asked: “Can a company provide or sponsor websites that include user-generated text and content?”

Under the current rules the answer to this is ‘no’. So the group suggested several possible answers that the rules could then be changed to give, including:

• This can be done, but companies must monitor and control such content in online areas they commission, initiate or control (including social media sites)

• Discussion areas/forums are acceptable, but content must be monitored at least once a day – comment threads about off-licence topics, or other areas that wouldn’t comply with the Code, must be removed within three days

• Text should be moderated and approved before publication

• Any pharma company entries must be made by a member of the medical team acting in an official capacity, and readers must be made aware the entry comes from a company employee.

“User-generated content does merit some consideration going forward,” Heather acknowledged. “But I wouldn’t hold your breath given what’s going on in Europe.”

The whole area was, she concluded, “very problematic” for pharma companies.

Another area of particular interest was the use of search engine optimisation (SEO) by pharma companies to improve the rankings of their websites so they appear higher up on, for example, a page of Google search results.

Heather said SEO was “probably justifiable” if responsibly and appropriately done, adding: “[It’s] about being sensible and appropriate. At the end of the day you don’t want to promote medicines to patients, or to be in breach of the Code.”

Some less pertinent issues were also addressed, such as the use of chat rooms and the number of banner adverts allowed on a website – a spill-over from the current Code restriction on the number of adverts allowed in printed journals.

“Generally complaints are about printed material or what is said by reps,” said Heather. “I don’t see [banner ads] as such a huge problem.”

A lack of guidance need not stifle digital innovation

“There is a lot under the Code that you can do,” she said, echoing her comments last year that pharma is not yet doing everything it can with Web 1.0, let alone Web 2.0.

Whatever activity was undertaken Heather said: “You need to think about how you’re going to defend what you’re doing. How would you justify it? How would you feel if you were your competitor?”

The Code of Practice was last updated in 2008 and we may see a new version by the end of this year, but it is unlikely to satisfy those who want to see chapter and verse rules of every aspect of digital marketing.

This seemed to be confirmed when Heather said she wanted to take a more pragmatic approach to how digital media is viewed under the Code, rather than putting definite rules in place.


Before Heather Simmonds spoke, Janssen-Cilag’s communications manager – and PM Society working group member – Alex Butler gave an interesting presentation on Health 2.0.

This is, broadly speaking, the concept that social media can promote beneficial collaboration between patients, carers, the medicine profession and other stakeholders in health.

“The revolution of social media is the most important change to healthcare since the inception of the NHS,” Alex said, pointing to how real-time, global sharing of information had fundamentally altered the doctor-patient dynamic.

“This time the patient really is in control. The real key opinion leaders are patients and the public.”

His rapid-fire presentation took in the benefits of participating in social media, but also the occasional challenges of doing so, and he finished with some questions on pharma’s traditional bête noire when it comes to digital, the adverse event.

“Why are we constantly talking about how to avoid adverse events? We need more real world information and greater patient engagement,” he said, suggesting the real question was: “Do we genuinely want to listen to what people are saying? Are we ready to meet the challenge of capturing real world data?”

• What do you think? Can pharma meet the challenge of capturing real world data? Does the UK industry need more rules – or should it just read the existing Code more carefully and then innovate? What would prompt you to try more digital marketing?

Please add a comment below (registration required).

Dominic Tyer is web editor for Pharmafocus and and the author of the Digital Pharma blog He can be contacted via email, Twitter or LinkedIn.

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