Article
Social media risk management guidelines for life sciences companies
Dec. 6, 2022 · Authored by Mario Prohasky, Morgan DiSanto-Ranney
Life sciences companies are continuing to rapidly grow their use of social media and digital channels as a form of communication with the public, healthcare professionals (HCPs), healthcare organizations (HCOs), patient organizations (POs) and others. Because of this, the International Federation of Pharmaceutical Manufacturers and Associations (IFPMA) and the European Federation of Pharmaceutical Industries and Associations (EFPIA) – both pharmaceutical trade associations – issued a joint guidance on social media and digital channels that applies to their member companies (i.e., companies and industry bodies who are a member of the IFPMA or EFPIA). This joint guidance will serve as an important new standard in an area of compliance that is rapidly evolving as a result of the growing and increasingly multi-faceted use of social media by the life sciences industry.
The IFPMA and EFPIA emphasize that this joint guidance will be continuously evolving. Nevertheless, it is also firmly rooted in compliance principles that already form some of the key elements of effective risk mitigation, such as the need for having a robust process when creating externally facing content or when engaging with external stakeholders.
The below sections highlight how this guidance uses and adapts some of these key elements of effective compliance in the context of social media interactions while also providing additional practical guidance for more robust risk management.
Summary of the IFPMA and EFPIA guidance on social media
There are four sections within the joint guidance that incorporate key elements of effective compliance in the context of social media interactions.
The social media and digital channels communication principles section notes several principles for member companies. A few highlights include prohibiting both on-label and off-label advertising; restricting access to promotional content/materials to the appropriate audience (e.g., only HCPs) as direct-to-consumer (DTC) advertising is prohibited in all countries except for the U.S. and New Zealand; ensuring generated or sponsored content is truthful, non-misleading, balanced, current and accurate; and assessing and verifying adequate information technology (IT) security.
The risk considerations section poses a series of questions for member companies that can be insightful in assessing digital communication risks and appropriateness of digital channel content, access, set-up and maintenance.
The member guidance for this section touches upon the select digital channel types, including websites, social media platforms, blogs, podcasts, webinars, direct channels and discussion forums. The guidance emphasizes that the use of keyword optimization for websites to display high on search result lists needs to be appropriate for the intended audience and any unauthorized promotion to the public must be avoided. Additionally, member companies should ensure that any linked websites do not promote prescription pharmaceutical products to the public. Lastly, the guidance cautions member companies who are using social media platforms that limit or restrict their ability to monitor or access comments (e.g., encrypted apps).
The guidelines for engaging with online influencers and digital opinion leaders sections are noteworthy as other guidances have not touched upon life sciences companies' interactions with online influencers and digital opinion leaders. The guidance outright prohibits online influencers from promoting products on-label or off-label to the public (unless permitted under local law). Additionally, to avoid the perception of undue influence, the guidance recommends that the rationale for a company to engage with an influencer or opinion leader is both considered and documented. Also, services provided by online influencers and digital opinion leaders must serve a bona fide/legitimate need, and any compensation must be appropriate and reasonable. Full transparency of relationships with online influencers should also be ensured and disclosed according to local regulations.
