Why your pharma brand doesn’t need a digital strategy in 2012 January 3, 2012
Posted by Kay Wesley in CRM, Marketing.3 comments
Last year my New Year post was 5 things I’d like to hear from pharma marketers in 2011, and you may like to know I’ve heard 4 of the 5. (I’ll leave you to guess the one I haven’t heard yet.) This year, 5 things I really don’t want to hear in 2012 or ever again… What do you think?
1. I’m not sure that digital is important to my customers
There are a number of problems with this. First, referring to ‘digital’ as if it is one channel, which it isn’t. Second, just about everyone in the developed world, and a great proportion in the less-developed world, use some sort of digital communication. In many countries of the developed world internet penetration is now around 80% of the population. When you also consider that, worldwide, 34% of people are either under 14 or over 65, you realise that almost all of the student and working population is online, together with a good proportion of older and younger people.
It might be social media, email, SMS messaging or a variety of other types of interaction, but digital is very important to most of us. But as I said it is not one channel, therefore it is important to find out what digital interactions are relevant for each customer and when.
2. We have a dedicated digital team; our marketers/medical people/reps don’t need to know digital
Once again we are making the assumption that digital is somehow a channel when it is not – it is a capability that all communicators should have. Reputations are made (and broken) in digital spaces – therefore your PR team must be savvy and your employees require guidance. Medical education is increasingly provided and sought online – pharma medical teams must be active here. The ‘self-made KOL’ is emerging through blogging, HCPs reach out to each other in online forums and networks – key partnerships can be developed in these places. Brand visibility, services, information and interaction are expected from your customers – all members of your brand team and your sales reps must have digital tools in their kit.
Training all communicators to embrace digital in all its forms must be a top priority for companies that are re-organising for the digital economy. This and developing and embedding best practice is the role of your digital team, who should be very busy in 2012.
3. I tried a website and it didn’t work
Whenever I hear a ‘I tried <interaction-type> and it didn’t work’ I want to shout ‘DON’T BLAME THE CHANNEL’!
It is like saying ‘I watched Big Brother and didn’t like it, so I’m never going to watch TV again’.
There are various forms of this, often from people who were ‘bitten’ in the early 2000s when there was a lot of mediocre execution. Companies and agencies alike had not developed best practice in pharma digital and many mistakes were made. Email was too often spam, websites became out-of-date brochureware, banners were irritating interruptions. Tactics didn’t ‘work’ and brand leaders, perhaps already sceptical or perhaps having fought for the budget and been proved ‘wrong’, became disillusioned.
However, if you are taking a more strategic approach to your customer, intending to interact with them at the right moment with the right content in the right format to delight and engage them, at some point websites, email, banners may indeed be the right interaction. You just need to execute well.
Also beware of blanket advice from cross-industry digital experts. You sometimes hear for example that ‘ email is obsolete’ and this may be the case in some sectors, but it is often not so for physicians – studies show many still use and value email from colleagues and also email news from professional associations and pharmaceutical companies. The important thing, once again, is to understand what your customer wants and will engage with.
4. Prove to me the ROI of that digital tactic
It is self-evident that digital interactions are more scalable than face-to-face (engage 10,000 people digitally for a similar cost to engaging 1000, not so for a F2F meeting) and therefore the cost-per-interaction can be lower than some other types of interaction. But measuring ROI per tactic? Think about it – what is the ROI of a single rep visit? Taking a doctor to an international congress? Can you measure it? No. Why? Because the ROI is delivered (a) in the long-term (may be a year or two down the line) and (b) is a result of the entire relationship with the doctor, not that one tactic. A brilliant congress impact may be completely overturned by poor service subsequently by the rep or a bad website experience.
Digital interactions are so measurable I think we sometimes get carried away with our metrics and blind people with science. Yes, we can measure clicks, readership, time spent, where they came from, where they went, and all this is important to understand how well we executed the tactic and the overall campaign’s success.
But real ROI comes from the overall customer experience or relationship. For example, a physician may be invited to a webinar or online discussion by a rep, they may sign up online, receive a reminder email, attend the event and then receive another email inviting them to comment on the event and request next steps. We must measure the success of each of these steps (e.g. uptake after the rep visit, registrants who actually attend and so forth) but the ‘ROI’ of one tactic alone is meaningless.
What we can track is the ROI in terms of customer satisfaction and market share of those who took part in this overall campaign and those who did not. We can also track the relative preference for our brand in terms of brand choice/brand equity studies over time, and evaluate what interactions those who prefer our brands have received. In this way we can start building a picture of the right mix for different customers and how well we are executing.
But seeking out short-term ROI measures from individual tactics is meaningless. We don’t demand this of other channels and should not expect it from the ‘digital’ ones.
5. My brand needs a digital strategy
There is no such thing as a digital strategy for a brand. In fairness, my team and I do run ‘brand digital strategy workshops’ but this is shorthand for taking a strategic approach to embedding digital into a multichannel brand plan. And that is the way to think. How can I put my customer truly at the centre of my planning and consider all the interactions that will be effective and how to combine them into a seamless and delightful customer experience and long-term relationship?
There isn’t a one-size-fits-all answer to this in pharma, there isn’t a piece of software you can plug variables in and out pops the ‘channel mix’. You have to gather all the insight you can and take your best guess at the channel mix for your customer, execute with excellence and be ready to change the mix and iterate, iterate, iterate. Over time you learn what works for your brand and your customers in the market in which you operate. That’s where great measurement, analytics and CRM platforms come in – to help you ‘learn as you go’. But your first multichannel plan will have to be your best, most educated guess, drawing on all the knowledge and experience you can access.
Brands, in summary, should have a multichannel customer engagement plan – starting with a ‘channel agnostic’ planning process that evaluates all channels – digital and traditional – equally.
Companies, on the other hand, can – and should – have a digital strategy – by which I mean a strategic approach to embedding digital expertise and processes across the organisation. Only with the right competence in all channels can channel agnostic brand planning take place.
App-athy and the Wild West: eyeforpharma Mobile Strategies London Dec 2011 (#e4p) December 8, 2011
Posted by Kay Wesley in CRM, Marketing, mobile.2 comments
At last week’s excellent eyeforpharma Mobile Strategies event in London (1-2 December) there was an interesting dichotomy between how embedded ‘mobile’ seems to be the lives of the delegates and how far from embedded it is in our professional communication strategies.
In a mini-poll I did as Chair of Day 2, 75% of the delegates had an iPad, 86% a smartphone. Three-quarters of delegates had used their phone as their alarm clock that morning, the same number admitted signs of anxiety if they didn’t have their phone and would not leave home without it.
Yet still we are not necessarily drawing on our personal experiences in order to develop the insight to deliver value for our customers. Here are my five take-aways:
1. Mobile App-athy
Brand teams and marketers in pharma are excited about the potential of mobile apps but our customers are perhaps less enthusiastic. As a result there is a large number of pharma-sponsored apps (one estimate put the total health apps at 34,000) with just a few downloads each. A panel discussion (chaired by Chad Daugherty from Lilly with Len Starnes – @lenstarnes, Duncan Arbour – @rbour and Andreas Claus Kistner) concluded that pharma is too keen to invest in “shiny things” without real insight into customer needs.
Companies want apps but many have not optimized their email and websites for mobile – even though doctors and patients use mobile devices mostly for email and websites. Too many emails will not even display properly on a mobile device, and Sam Walmsley (@sammielw) pointed out that only 12 of the top 2 pharma companies’ websites are mobile-friendly.
To me it feels like the late ‘90s when brand managers everywhere were saying “I want a website” without taking a strategic look about how the web might fit into the overall communications plan. Many useless websites later, companies started taking a more strategic, customer-centric view and websites grew up.
My advice – if your objective is to build an app, don’t. Spend time defining an objective that is about customer value, then see what channels/tools can achieve it.
2. The Mobile Physician – who?
We learned that Doctors download 50 apps on average, but like everyone else, use just 7 regularly.
A panel discussion with Doctors Rob Hicks (@DrRobHicks), Peter Ilves and Henrik Andersson observed that there are “mobile” and “non-mobile” doctors. “Mobile” doctors are doing hospital ward-rounds or travelling from patient to patient and need handy reference services in their pocket – often it is treatment guidelines, symptom checkers, calculators. One example of a this is the Psoriasis PASI calculator from Janssen, a simple tool to help determine the severity of the rash and therefore appropriate treatment.
“Non-mobile” doctors are sitting in their office seeing patients and will mostly use a laptop or desktop computer. We need to provide multichannel services to fit the requirements of each.
One interesting doctor-patient app we saw was the mini-atlas from EC-Europe – anatomical atlases for iPad, designed for doctors to share with patients, the most recent version of which allowing the doc to draw on and annotate the image, then send to the patient. Pharma companies are sponsoring these atlases and the platform is well chosen – 93% of tablets sold to HCPs in the US last year were iPads.
Rob Hicks put it simply: the doctor’s daily workload is already very high and overloaded with multi-channel information – ““Don’t give us lots more to do – give us stuff that will save work and time.”
3. The Mobile Patient and mHealth
MHealth is now an established force in the developing world, where mobile technologies are providing much-needed access to health care and changing lives. In the developed world, however, the picture is more fragmented and, as for physicians, there are a great many under-utilised health apps competing for attention in the app store.
The winners are once again those based on real customer need and insight. For example the Claritin pollen alert for hayfever suffers (I can testify to its usefulness); Medtronic’s Lenny the Lion ‘carb-counting’ game app for children with diabetes, and a sponsored app in Israel for finding the nearest public WC, with links to Pfizer’s advice about bladder control.
The most compelling opportunity to provide mobile health solutions we saw was not for the “walking well” – the traditional pharma targets of asymptomatic patients needing medication reminders – but the moving and inspiring story from the Teenage Cancer Trust. Presented by Simon Davies, CEO, Professor Faith Gibson and former patient-now JimmyTeens.TV developer Tom de Bruin (@deadlyhifi), this told of the problems faced by young people going through chemotherapy.
Isolated by necessity and often very ill, these teens feel even more alone if they turn to Facebook and see their friends having fun without them. They also have a million questions and concerns about their symptoms (as do their parents). The Trust has pioneered web-based solutions allowing patients to ask questions of a cancer nurse and get help, information and support online, as well as connecting with other patients. The mobile potential for this is exciting, and so the Trust and eyeforpharma are running a competition to design such an app.
4. Ready, Fire, Aim! – Reps and iPads
I have stolen the title from Armand Brevig (@BuyingeContent) of Reprints Desk and several of the speakers agreed with the point that companies have taken a “Wild West” approach to iPads for reps, in some cases providing the technology before any application has been identified. Back to those “shiny things” again.
However, there is hope. Roche has integrated iPad solutions for its reps. In the pilot reps said that the ability to update the CRM system right there after the call was saving them 2 hours of data entry each evening. Key learnings: keep it simple and quick, provide offline capabilities, integrate with the rest of the solution (not ‘islands of technology’) and learn to fail fast and learn from mistakes.
My favourite quote of the event is Andreas Claus Kistner’s definition of ‘fail fast’: “Technology is like chocolate, if it is fundamentally bad, you can’t fix it – throw it away and get some new stuff.”
There was also an interesting example from Murat Mendi of Nobel, who rolled out a fully integrated and tracked closed loop marketing system in Turkey with 100% rep adoption based on tablets, not iPads – demonstrating that CLM is about good strategy, strong execution and shifting the culture, regardless of technology.
5. Good Mobile Service/Marketing is Just Good Service/Marketing
Our (@CompleteDigital’s) own Helen Harrison (@harrassedmom) set the tone early on in the event with a story about how the First Direct bank – famous for award-winning customer service – developed their mobile app.
As a bank they had some parallels with our industry – they had a mountain of legal, security and personal data concerns and had to very carefully step through the hurdles and ensure high standards of compliance.
Priding itself on being the top bank in terms of customer satisfaction in the UK, First Direct started with its customers. The team developed clear and detailed customer personas and designed the app with the user at the centre. They chose not to do “everything” but to do the few key things that customers really wanted, really well. They tested, tested, tested, including sketching the designs on paper and sitting with customers refining them, then testing further at wireframe and design stage so that by the time the app was built it needed hardly any testing – it was exactly what customers wanted.
In other words, First Direct did the opposite to “I want an app”, they spent a good deal of time investing in finding out what their customers really wanted, then delivered it. With 100,000 downloads in the first month and 85% 4 out of 5 rankings, it seems to have hit the mark.
Medtronic’s Matt Thomas re-iterated this on day 2 when he advised us to start with the strategy, learn from observing customers and continually analyse in order to refine the service.
The best healthcare mobile solutions, like the best banking solutions, do exactly what customers want, really well. In Helen’s words and put very simply, mobile apps or other mobile solutions must adhere to the first rule of great customer service:-
SUCCESS = WORK NEEDED BY USER < VALUE OF SERVICE
Simple, really.
How can pharma cross the Digital Chasm? August 24, 2011
Posted by Kay Wesley in Marketing.add a comment
How can pharma cross the Digital Chasm?
Once upon a time, an HR Director in a large organisation was trying to place me in the pigeonholes of corporate life. Jolly as one is when the focus is “all about me”, I talked through the jobs I’d done. Lab researcher, programmer, analyst, product manager, customer service manager, training manager, marketing director, VP strategic marketing, global e-marketing director, global brand comms director. “What do you like most?” was the question she patiently asked, looking into my eyes, and, she hoped, no doubt, my inner self.
“Change” I replied without thinking.
“Er, I meant, which particular job role were you most comfortable in?”
(pause)
“Well, it’s best for me when I’m not comfortable…”
Like you, I’ve been on the leadership programmes, the “solution-selling” and “customer-centric-marketing” and “marketing excellence” initiatives. But I’ve long been a student of human folly, and one thing has consistently struck me, through all the changes I’ve seen (test-tube chemistry to computerised micro-samples, punched cards – I kid you not! – to augmented reality, sneaker-net (carrying floppies across the office) to cyberspace, and so on) is the way human beings react to and embrace (or not) change.
Geoffrey Moore had it fairly spot-on in his seminal work Crossing the Chasm (originally published 1991).
Moore’s hypothesis is that adoption of new technologies does indeed follow a normal distribution (as originally described by Joe M. Bohlen, George M. Beal and Everett M. Rogers at Iowa State University.)
In other words, from a small number of ‘innovators’ (the techies who play with the new stuff for its own sake) to a larger number of ‘early adopters’ (who see the possibilities of the new technology and are willing to put up with the fact that it is unfinished because they are visionaries) through to the ‘early majority’ – the mainstream early users – followed by the ‘late majority’ and ultimately the die-hard ‘laggards’.
What was different about Moore’s hypothesis is that he said if the technology is ‘disruptive’ (i.e. completely unprecedented – not “faster horses” but “the motor car” – as per the famous supposed Henry Ford quote), then there is a very large gap between the early adopters and the early majority – the CHASM.
The early adopters have these characteristics: they give credence to the innovators and listen to them; they can translate from tech innovation to business success; they are willing to “finish” the product with their own resources, recognising it is new and may require considerable development to be a commercial product; they understand it is unproven and will take the risk, they will invest and put themselves on the line because they believe in the new innovation.
However, the early majority are totally different. They want a product that is complete, stable and supported; they expect it to have proven return on investment; they expect a good support infrastructure; they want to know the product is reliable and has good references, they will not risk their reputation on the new technology. Why should they?
Therefore, the worst person to sell a new technology to the early majority is, in general…the early adopter.
I have had personal experience of this. In the early 90’s I was working on a market-leading financial software product and we were introducing the brand spanking new ‘Windows’ version of the product, that would replace the much-loved and very successful DOS product. (If you actually know what I’m talking about, by now you should probably be sitting in your armchair in your carpet slippers with a newspaper and a nice dry sherry by your elbow.)
We had recruited client development partners, run focus groups and had an extensive beta test program, and were very confident that the new Windows product would (eventually) have all the capability of the DOS version and would be much easier to use.
At about this time, the great ICI de-merger was happening and Zeneca Pharmaceuticals was being born, leaving ICI as a paints and agrochemicals business. True to expectation, ICI retained the DOS financial product and Zeneca, the new kids on the block, wanted the new-fangled Windows version. I remember working with them for months on the implementation. It was a very happy and productive collaboration.
And most of all I remember our annual user conference, when the very lovely Financial Systems Director of Zeneca (JP, you know who you are) stood on a platform and told 300 Finance Directors, Financial Controllers and Financial Systems Managers (the keyword here being “finance”) that he, and Zeneca, had had “hundreds” of people working on this new platform and spent “millions” on the implementation of the new Windows software. For him, the size of this was impressive and good for his CV. Not so for me. I looked round the room and saw 300 aghast faces and the biggest own-goal of my career looking back at me. Not a single person in that room was going to migrate to the Windows product. (Well, they did eventually of course, but that event didn’t contribute. Not one bit.)
That was the day I fell right into Geoffrey’s Chasm.
Now, almost 20 years later, I consider where we are with Digital Pharma. The innovative brand managers and eMarketers have run pilots and by gum, we’ve shown return on investment. Everyone KNOWS that customer-centric marketing, with digital as a core component, is the future, right?
The problem is, the early adopters in our industry are not turned on by “training” or “embedding” or “standard operating procedures”. So the visionaries who were building websites 10 years ago are now off building apps…and still “websites” are not core to our brand communication plans – although in many cases they probably should be. A brand manager in any other industry would be reprimanded if their product website wasn’t number 1 in Google for the brand name in their country…but for pharma brands it is a rare thing when they are.
Our industry culture doesn’t help. We reward “innovation” not “embedding”. A forward-thinking brand manager who does exciting new stuff that seems to work is quickly promoted to another, often regional or global role, leaving the innovative new practice to wither on the vine.
Meanwhile our core business model is 50 years old and creaking at the seams. What we must have is the leadership will and the management skill to really embed a digital/multichannel customer engagement culture, backed up with everyday stuff like training, best-practice documents, standard operating procedures and day-to-day mentoring and coaching in new ways of doing business.
The pharmaco that cracks this first, will be a winner. Will it be you?
5 things I’d like to hear from pharma marketers in 2011 January 25, 2011
Posted by Kay Wesley in Marketing.Tags: Marketing
4 comments
1. Digital is a core skill-set required for all marketers in our organisation.
In FMCG, in banking, in the media, this has been true for years. But in pharma we still seem to think that the eMarketing person “over there” will deal with all the digital elements of our brand plan.
This is a bit like having a brand team member whose job it is to look after “paper”. But “paper” isn’t a channel, and neither is “digital” – they are both types of media with many different manifestations and many channel types, and digital opportunities present themselves in public relations, medical education, brand promotion, KOL discussions, customer relationship management, among many more.
All our communicators, from the medical information team to the board of directors, must be digital-savvy. As the power-house of communications, the marketing team should be leading the charge and ensuring that all marketers are e-marketers.
2. We are evaluating whether or not to use face-to-face selling for this product/customer segment/country
We all talk about customer-centric multi-channel marketing. But do we really challenge our accepted channel mix? How brave are we? Do we evaluate whether these target doctors prefer face-to-face or other types of interaction – the way we (still!) ask if digital interactions are relevant?
Or is our planning still centred on the goal of getting reps in front of doctors? Assuming we feel there is a role for a mix of human AND digital interactions are we optimising the cross-channel opportunities? Are the reps passionate about and selling our digital support services? Are our digital interactions offering face-to-face follow up?
3. It is our duty to try to ensure public sources of information about our products are up-to-date.
Most pharma companies are aware that patients and doctors use public online sources like Wikipedia as much as, or more than, “official” sources of information. Most regulatory authorities do not prevent the industry from sponsoring updates to such sources to ensure their currency and accuracy. But still, most pharma companies are not doing this and most of these sources are out of date. Shall we find a way to fix this in 2011?
4. I am well aware of the online conversations about my drug, and this insight is shaping my strategy
2011 is the year to really start listening. Yes, use an agency and a monitoring service to regularly report on the conversation. But, just as important, go there yourself and listen. To be a “fly on the wall” as your customers discuss your product or the needs they have that it might address is a marketer’s heaven. Let’s make use of it.
5. Is it unproven? Do we think it might work but don’t know the ROI? Let’s do it!
How many times have you been to those meetings where you brainstorm innovative communications, and come up with a number of real “breakthrough” communication ideas that you think, with all the knowledge in the room, will really impact your key target audience, change behaviour somehow, and change healthcare forever.
Then someone asks the million-dollar question “how do we know it will work?” and everyone looks round uncomfortably. If it doesn’t work, you’ve wasted the company’s money and you look like a fool. If it does work, you might create a communications paradigm shift and become a hero.
Generally in the pharmaceutical industry, we don’t reward risk. We don’t risk taking a drug to market until we have all the clinical evidence it needs to support it, and so often we mirror that behaviour in our marketing plans. If we don’t have evidence to support a course of action, we don’t do it. This is impacting our readiness to adapt our mix to exploit emerging channels. We want first mover advantage, but wait a minute, we don’t want to be first.
Happily, we are seeing “innovation funds” and “digital strategy leaders” and increasingly people whose job it is to try things and see if they work. This is a promising trend, but still the risk-averse culture is embedded, and the only people who can change our culture is…..us.
Set aside a portion of your brand budget as the “risk fund”. Reward your team for taking managed risks and learning from them. Adaptability can create competitive advantage. Let’s do it!
My takeaways from the PharmaBrand Summit June 28, 2010
Posted by Kay Wesley in Marketing.3 comments
Last week’s PharmaBrand Summit in Monaco was attended by about 120 senior pharmaceutical industry experts from companies and agencies. This summit is about key trends in the market and how the industry is responding.
Over the 3 days, four themes kept surfacing – emerging markets, the opportunity of digital to engage consumers, the importance of the payer and the need for a different mindset.
Right from the Chair’s (Ashish Pal from Merck) keynote the importance of emerging markets was clear. 90% of the growth in the next 10 years will come from EMs, with infectious diseases and women’s health (contraception) among some key growth areas. A panel discussion concluded that agility, adaptability (recognising that each market is different) and the willingness to appoint and develop local talent rather than parachute in ex-pats are vital.
Digital channels raised their head many times, especially with regard to engaging consumers and patients. I heard the phrase “awakening the European consumer” which, to be honest, I find a bit naive. European consumers (consumers everywhere) don’t need us to “awaken” them – they are very much awake and active with or without us! There was also a tendency to say “there’s not much we can do in social media because we can’t promote to consumers” as if “promotion” were the only possible way to communicate with people. That is a mentality we need to leave behind. More on this shortly.
Payers were the focus of day 2 with Janice Haigh of Astellas Pharma explaining “the Art and Science of Payer Marketing” and my colleagues from ConsultComplete, Ian Pickles and Zoe Gilbe, sharing some interesting Payer insight work, showing that healthcare models are converging, with all markets looking at co-pay models, and the need for product positioning to encompass the needs of all stakeholder in an increasingly complex environment.
The pharmaceutical industry game has changed and we must change too. There was discussion about bringing more people in from outside the industry, and changing our mindset. I enjoyed Gregory Miller’s (UCB Pharma) session. He has “commercial advisory boards” drawn from experts in OTHER industries to bring a fresh perspective. For example for a persistence issue in epilepsy he has invited people from other sectors where customer relationships and loyalty are paramount – like WeightWatchers, Nokia, Hertz, Miles&More – to be his ad board. So far implementing the learning from these ad boards has generated real results in terms of market share.
A wonderful example of a different mindset, using skills from beyond our industry to think differently and using multiple channels to engage consumers for positive results was Pfizer’s ground-breaking “Get real, Get a prescription” campaign, led by Andy Widger (ex-BBC).
This campaign’s goal was to reduce the sale of counterfeit medicines on the internet. It was executed using a number of channels including outdoor (actors dressed as builders mixing “drugs” in a cement mixer), print and the famous shocking “rat-poison” video that was shown in cinemas and late-night TV and has since gone global virally on YouTube and elsewhere. The campaign generated a great deal of press coverage, was supported by the MHRA, the Royal Pharmaceutical Society, Heart UK and the Patients Association.
There is evidence that over 5000 people in the UK are now not buying fake medicines that previously were – a small number but it’s a start. There are now moves to take the campaign global.
As a result of this program, Pfizer’s reputation has improved with the professional bodies involved – they are not sure about impact on the general public’s perception yet. This is a great example of using consumer channels to improve medicine, to support customers and to enhance the industry’s own reputation. Hats off to Andy and his team.
Overall it was an interesting couple of days and I met a good many global pharma leaders who are looking at changing how we do business. Very refreshing. If you were there, what did you think?
Eyeforpharma emarketing Berlin 2010 take-away No. 4: Regulators don’t always say No March 17, 2010
Posted by Kay Wesley in Marketing.Tags: Marketing, pharma, regulations
add a comment
Delegates from last year’s eyeforpharma eMarketing Europe had indicated that more insight into the thinking of regulators would be very helpful, so Heather Simmonds of the UK’s Prescriptions Code of Practice Authority bravely took the stage to discuss the changing landscape, both in the UK and across Europe.
The very different interpretations of what constitutes “promotion to patients” by different countries does not help companies trying to establish a European strategy. France and Germany consider the mention of a drug name to be “promotion” whereas the UK guidelines allow and even encourage companies to provide “reference information” i.e. factual information about medicines, to consumers, provided it is balanced, accurate and not misleading (check out clause 24 of the ABPI Code of Practice 2008). She observed that in the UK many pharma marketers are currently not doing what they are allowed to do within the code, so why ask for codes to be broadened?
Consequently different countries are reacting differently to the proposed European Directive on information to the public about prescription only medicines – effectively this will relax the rules in some countries and tighten them in others.
The codes in many cases are already in place and just need to be interpreted for online. For example, information you can provide in a closed meeting to doctors can probably be provided in a closed website to doctors.
It only becomes an issue when the translation is not direct – for example, a passing question and answer in conversation, becomes a permanent record when written in a forum or blog – and as soon as that permanence is established it must be treated as a document and comply with the relevant code of practice.
Context is also important: a piece of patient information in one context might be balanced and neutral, but choosing a phrase from that information and displaying it differently might be deemed promotional.
Heather’s plea was to involve the regulators. They want to help us achieve goals of better medical education and healthcare and the discussion can be about not “can we or can’t we?” but “how can we?”
Notwithstanding this debate, the question still stands: in a global channel, if a piece of content is for a “global audience” whose national rules apply? It is not practical to consult every code in the world just in case a citizen of that jurisdiction comes across the content. Further, during a panel discussion, Silja Chouquet of Whydot.com asked “Who has lied about being from the US to gain access to one of their consumer websites?” A handful of hands stayed down – the US delegates, of course.









