Digital Pharma: Twitter slip-up shouldn’t silence pharma
pharmafile | September 9, 2011 | News story | Medical Communications, Sales and Marketing | Bayer, Code of Practice, Digital Pharma blog, PMCPA, Twitter
Bayer UK was recently ruled to have breached the ABPI Code of Practice by promoting prescription-only medicines to the general public via Twitter.
This was an embarrassing and unfortunate incident for the company, but I don’t believe it needs to scare UK pharma away from digital media.
I have to declare a particular interest in this case because I personally brought the breach to light though this column, and Pharmafocus subsequently alerted the PMCPA.
The case centred on tweets Bayer sent to its Twitter followers to promote two medicines – the launch of a new orodisperable version of its erectile dysfunction treatment Levitra and the launch of multiple sclerosis spasticity drug Sativex.
At the time the @BayerUKIreland account had around 500 followers, some of whom were clearly members of the public.
This represented a clear breach of Clause 2 of the Code, which outlaws the promotion of prescription drugs to the public.
In its response to the PMCPA Bayer said the majority of its followers came from groups that had “a special interest in Bayer’s businesses” – such as journalists, agencies, consultants and competitors.
But the company acknowledged it was not possible to identify exactly who its followers were due to the way Twitter works.
On re-examining the tweets at the PMCPA’s behest, Bayer accepted they did indeed constitute advertising to the public and an encouragement to request a specific medicine.
The company acknowledged breaches of Clauses 22.1 (for advertising prescription-only medicines to the public) and 22.2 (providing the public with information that was not factual or presented in a balanced way), but had hoped to avoid breaches of Clause 2.
Bayer said it was “an ongoing challenge for the pharmaceutical industry to decide how it could use digital media and still ensure it respected the long-established restrictions on promoting its products”.
But the PMCPA panel was particularly concerned Bayer had not had its tweets certified for Code compliance and it was this mistake, and how it came about, that led to the Clause 2 breach ruling.
“If part of a certified document was reproduced in a different format or directed to a different audience the new material should be certified separately. The panel was extremely concerned that controls within the company were such that uncertified information about the launch of prescription-only medicines had been posted to Twitter.
“The nature of dialogue on Twitter was such that tweets were broadly and quickly disseminated,” it added.
Tweet in harmony with the Code
The panel reiterated the PMCPA’s position that use of social media, including Twitter, was a legitimate activity for UK pharma as long as the material complied with the Code.
So does this mean that Twitter is an absolute no-no when it comes to promoting medicines? Not necessarily. Twitter can be used in a ‘private’ mode so only users you approve –i.e. healthcare professionals – can see them.
However, a closed Twitter community would be far less likely to flourish, and it would also require several extra (time consuming) steps such as verifying doctors’ identity and their willingness to receive product communications).
Media coverage
Once the PMCPA confirmed that Bayer would be ‘named and shamed’ in the pharmaceutical press, there was considerable media interest.
Most notably the Financial Times pronounced it “a pioneering case highlighting the dangers of social media for marketing” and went on to suggest it “highlights fresh scrutiny by international regulators of innovative social marketing techniques”.
This seems like an interpretation too far, for me. It is indeed the first case of its kind, but it only highlighted the danger of social media in the way that other cases highlighted the danger of clinical support services, advertising and hospitality; they’re only dangerous if they’re used in a way that breaches the Code.
The case is sure to give communications professionals within pharma pause for thought, but the error did not spring from any technological difference between Twitter and traditional media channels.
At its heart it was a case of naivety and not deliberately nefarious practices, unlike some of the worst examples of Code breaches over the years. So, though warranting a Clause 2 breach, it should be a case to learn from and not one that causes UK pharma to fear social media.
Dominic Tyer is web editor for Pharmafocus and InPharm.com and the author of the Digital Pharma blog He can be contacted via email, Twitter, LinkedIn or Google+.
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