The purpose of the note is to serve as a non-binding resource for pharmaceutical companies that are members of the IFPIA association, to facilitate the management of activities or initiatives intended to be developed in the digital environment in accordance with applicable laws, regulations, and industry codes.
The Note for Guidance covers the interaction of the pharmaceutical industry with Healthcare Professionals (HCPs), Healthcare Organizations (HCOs), Patient Organizations (POs), and other stakeholders.
The main risk to be avoided is that prohibited drug promotion may be carried out through social networks. To avoid this, the Note recommends taking a "pragmatic and vigilant approach".
Onus on the pharmas
To this end, the EFPIA reminds parties that member companies are responsible for all content disseminated via a digital channel, including social media when the content is initiated, branded and/or sponsored by the member company or a third party acting on its behalf.
Therefore, it is the pharmaceutical companies that must take an active position and adequately monitor corporate initiatives, the content that their employees may share on social media (related to their company or any drugs), implement adequate pharmacovigilance procedures, and manage data protection, among others.
On the other hand, it is essential to define the objective pursued by the dissemination of content as well as the audience it is intended to reach, and how the digital initiatives promoted by the company are reviewed and monitored.
In the final part of the Note, some instructions are given on interacting with online influencers and digital opinion leaders. It is advised to evaluate each interaction carefully, as well as the context, and the risks of (i) undue influence towards HCPs, patients or vulnerable groups, and (ii) improper promotion of pharmaceutical products.
In conclusion, although the Note has a rather generic content, and does not specify concrete limits to practices, it is a very beneficial initiative for the sector given the need to have clear limits in an area where the interest of pharmaceutical industry has increased in recent years. It will be necessary to follow local associations of Pharmaceutical companies to see how they decide to implement the provided Guidance.
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