Digital marketing masterclass for branded

materialsSpeaker: Dannie Newman, Reviewer, PAAB

Agenda

• Understand how target audience and product schedules intersect to determine the regulations relevant to advertising (consumers)

• Creating digital tools: What do you need to know and how to link assets in a compliant manner

• Work on cases to cement your understanding of regulations relating to SEO and SEM

Identify your audience

Consumers: Messaging directed to the general

public. Readily accessible by individuals who have not been prescribed the product.

Patients: Messaging directed to individuals

prescribed that product OR messaging in a tool intended for use by HCPs only during counseling.

Healthcare professional: Messaging directed to

licensed members of the professions of medicine, dentistry, naturopathy, nursing, pharmacy and related health disciplines and institutions.

Communicating with Consumers

Consumer Advertising or Consumer Information?

What is Drug Advertising?

Definition in section 2 of the Food & Drugs Act:

“Any representation by any means whatever for the purpose of promoting directly or indirectly the sale or disposal of any food, drug, cosmetic or device”

Still unsure?

See the Health Canada policy document:

“Distinction Between Advertising and Other Activities”

Can be found on the Health Canada and PAAB website.

Distinction Between Advertising andOther Activities:

• What is the context in which the message is disseminated ?

• Who are the primary and secondary audiences ?

• Who delivers the message (the provider) ?

• Who sponsors the message and how ?

• What influence does the drug manufacturer have on the message content ?

• What is the content of the message ?

• With what frequency is the message delivered ?

Breaking down the 7 questions.

1. Content /creation factors:

What is the content ?

Who sponsors the message and how ?

Extent of drug manufacturer influence over message content ?

2. Distribution/availability factors

Audience ?

Context of dissemination ?

Who delivers ?

Frequency of delivery ?

“No one factor in itself will determine whether or not a particular message is advertising.”

…If uncertain, don’t hesitate to ask PAAB.

We’ll respond to requests for written opinions within 4 days.

Communicating with Consumers

For Consumer Information (non-advertising):

Need to consider the relevant provisions from the “Distinction” Document.

Examples:

Help-seeking Messages

Consumer Brochures

Help-seeking Messages

Consumer Brochure

Consumer Brochure

Communicating with Consumers

For Consumer Advertising:

Need to consider:

product’s federal schedule &

whether disease/condition treated is on schedule A.

Consumer Advertising Regulations

Prescription

drugs

…Some products may have a dual Federal drug schedule

“Choose HerpRexfor the prevention of HPV”

Prescription

Disease Consideration - Schedule A

• Acute alcoholism• Acute anxiety state • Acute infectious respiratory

syndromes • Acute psychotic conditions• Acute, inflammatory and

debilitating arthritis• Addiction, except nicotine

addiction• Appendicitis• Arteriosclerosis• Asthma• Cancer• Congestive heart failure• Convulsions• Dementia• Depression• Diabetes• Gangrene

• Glaucoma• Haematologic bleeding

disorders• Hepatitis• Hypertension• Nausea and vomiting of

pregnancy• Obesity• Rheumatic fever• Septicaemia• Sexually transmitted

diseases• Strangulated hernia• Thrombotic and embolic

disorders• Thyroid disease• Ulcer of the gastro-intestinal

tract

See Health Canada website for list of Schedule A Diseases

DIGITAL ACTIVITIES

eDetail Aids, Apps, Websites, emails, social media

Critical Considerations

forany e-media

type

i) The intent of the message:

Is the intent of the message to promote a drug, disease awareness or a company?

ii) The target audience solicited:

Is the information targeted towards healthcare professionals, patients or the consumer?

iii) The type of drug product:

Does the information pertain to a prescription, non-prescription, vaccine or natural health product?

iv) The nature of the online content:

Does the site allow for dynamic content or is it static (i.e. entirely controlled by the sponsor)?

Key considerations when building a product website

CONTROL OF ACCESS

CONTENT LINKAGES PROMOTION OF WEBSITE

Access Control

• If the content exceeds that which is allowable in a consumer context, there must be a barrier to keep consumers out

• It is the sponsors responsibility to ensure sufficient mechanisms to determine the regulatory category of the person requesting the information online

Creating an acceptable barrier• Registration and/or attestation alone are NOT

sufficient barriers

• Password required for entry (controlled distribution)

• Professional License #

• Arbitrary set of characters selected by manufacturer

• URL of a website which is not indexed

• “keys” which bypass the barrier (controlled distribution)

• CD, webkey, email

• Access through moderator approval (with verification on the front end)

Remember: Landing page is accessible by the consumer

Let’s look at our product website for Jensulin

HCP website landing page

About PAABPharm.ca

Revisions required?

About PAABPharm.ca

Links to page on PAABPharma - approved for DTC use.

Welcome to JENSULIN.ca, your JENSULIN Resource Center

This site contains:- Information on the efficacy of JENSULIN- Guideline Recommendations- Lifestyle tips and programs for your patients- And so much more

Lets get started learning about JESNULIN

Enter your professional licence number here:

*This site is intended for Healthcare Professionals

Content

Websites tend to house large amounts of content

Websites are not typically read in their entirety within a single sitting

Difficult to predict the path users will take through the site.

Challenge:

Effective placement of fair balance (for HCPs)

Solution:

Indication & fair balance on the home page (or beginning of each section containing product claims)

A prominent “Safety Information” menu item visible from any screen on the site

Disclosure of Company

Name

• The name of the pharmaceutical company sponsor should be stated clearly on:

i) Every page of the web-site controlled by the sponsor

ii) On every sponsored web-page of a site with no access control

Homepage

Homepage

About PAABPharm

Safety Information

Linkages

Making Compliant Connections

Linkages

• Principles:

– If you join “advertising” and “non-advertising”, everything becomes “advertising”

– Branded and unbranded disease info • Internet links

• Product Package shot

Linkages• Consider:

• Proximity• Appearance• Sequence• Context

• The sponsor may link to corporate global sites only by linking to the global site home page. The sponsor should not link to the global site product pages/sections.

Linkage

Brand website landing pageUnbranded disease info

Linkage

Unbranded disease info

Colour gradient

Brand visuals

Branded Patient Website

Branded HCP website

HCP direct branded mailerSocial Media

campaignWellness/adherence

reward program

Corporate website

Linkages:

Branded Patient App

Branded patient websiteBranded HCP website

• Branded HCP website to a patient branded website

– Both branded, different audiences

– It is acceptable for the HCP to be exposed to patient material

• Branded patient website to branded HCP website

– Both are branded, but HCP content should not be promoted to patients

Branded patient website

Branded App – Patient support program

• Branded patient app to a patient branded website and vise versa

– This is deemed acceptable and does not change the regulatory status of either platform

Branded patient website

• Patient branded website to corporate website

– Link from branded pre-gate landing page – Not acceptable

– Link from any page post-gate – can link to the homepage

Corporate website

Branded HCP App or HCP website Corporate website

• HCP branded website to corporate website– Link from branded pre-gate landing page – Not acceptable

– Link from any page post-gate – can link to the homepage

• Corporate website to branded HCP app/website– Must link to the landing page – haven’t verified regulatory audience

yet

Branded HCP App

Wellness/adherence reward program

• Branded patient or HCP app linking to an unbranded wellness/adherence reward program

– Unbranded now has to be reviewed in the context of the brand

– Copy which may have been acceptable in the unbranded context may now be challenged

Branded Patient App

Branded HCP App

Social Media campaign

Branded Patient App

• Branded HCP app or patient app linking to social media campaign

– Branded (previously reviewed and approved by PAAB) - OK

– Unbranded disease support group/chat room/blogger

• Sponsors responsibility to ensure that the content meets branded patient regulations

– Violation could affect the acceptability of one or both channels

Promotion of a website

• Search Engine Optimization

• Search Engine Marketing

Search Engine Optimization

(SEO)

Regulations apply to any meta data text provided by the manufacturer (or it’s agent) to a search engine

• Descriptors under control of the sponsor should be submitted for preclearance• Must not exceed consumer advertising

regulations.

• Must not refer to competitor products.

Search Engine Marketing

(SEM)

Meta data requirements are the same as SEO with the addition of sponsor purchased keywords (s.6.5.11)

SEO Keywords

URL Meta description H1 tag Keywords

Jensulin.ca Jensulin.ca, an online resource

designed to provide valuable

information about Jensulin for

healthcare professionals, diabetes

patients and the general public.

Taking Jensulin? Diabetes

Insulin

Glycemic control

Hypoglycemia

Jensulin.ca/

patientlogin

Jensulin patient information Taking Jensulin? Diabetes Patient

Jensulin.ca/

hcplogin

Jensulin information for healthcare

professionals

Jensulin for

healthcare

professionals

Healthcare professional

Diabetes treatment

Jensulin.ca/

talktodoctor

See icebreakers to help you talk to

your doctor about hypoglycemia,

low blood sugar and more.

Help talking to

doctors

Talk to your doctor about

low blood sugar

Jensulin.ca/

realdeal

Learn the dangers of counterfeit

products

Dangers of

counterfeit drugs

Counterfeit

Real Jensulin

Jensulin.ca/

seenontv

See the latest Jensulin commercials

online

As Seen on TV

SEO Keywords

URL Meta description H1 tag Keywords

Jensulin.ca Jensulin.ca, an online resource

designed to provide valuable

information about Jensulin for

healthcare professionals, diabetes

patients and the general public.

Taking Jensulin? Diabetes

Insulin

Glycemic control

Hypoglycemia

Jensulin.ca/

patientlogin

Jensulin patient information Taking Jensulin? Diabetes Patient

Jensulin.ca/

hcplogin

Jensulin information for healthcare

professionals

Jensulin for

healthcare

professionals

Healthcare professional

Diabetes treatment

Jensulin.ca/

talktodoctor

See icebreakers to help you talk to

your doctor about hypoglycemia,

low blood sugar and more.

Help talking to

doctors

Talk to your doctor about

low blood sugar

Jensulin.ca/

realdeal

Learn the dangers of counterfeit

products

Dangers of

counterfeit drugs

Counterfeit

Real Jensulin

Jensulin.ca/

seenontv

See the latest Jensulin commercials

online

As Seen on TV

Subject to consumer regulations; should not identify the therapeutic area

Keywords: Jensulin

Gensulin

Jennsulin

Jensalin

Insulin passad

Diabetes

Injection

HbA1c

Hyperglycemia

Hypoglycemia

Foot care

Blood sugar

Safety profile

Prescribe

Ad related to Jensulin

Jensulin | Jensulin.cawww.Jensulin.ca

Learn about diabetes treatment

ExamplesIf Schedule D and not for the treatment of a schedule A disease:Vaccinator® (11 characters) For prevention of [something bad] (31 characters)Ages 15-55. For risk/benefit info…: (34 characters)http://www.vaccinator.ca

If schedule F:

Arbace®

Learn more about Arbace. http://www.arbace.ca

Summary:

• Composite of the user generated keyword, the metadescriptor, the landing page, and the Uniform Resource Locator (URL) must not exceed consumer advertising regulations.

Questions?

Questions?

Questions?

Virtual Community

CUSTOMER ENGAGEMENT

SHARE INFORMATION

LARGER AUDIENCE

INCREASED RISK

Scope of Online Activities

Apply to all online advertising activities which are:

within the sponsor’s control or influence

and where the intended audience is Canadians.