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Constructing pharma's Facebook wall

How pharma companies can manage their social media strategies following updates to Facebook's commenting policy

Facebook 'confirm' buttonOn August 15 2011, Facebook's new policy that prevents pharmaceutical companies from disabling comments on their Facebook Wall went into effect. Previously, the industry had been given a unique facility called "whitelisting" to prevent comments on brand posts, photos, and videos.

Facebook's ultimatum for healthcare companies to fully participate has caused many in the industry to question whether to remain on the platform, as strict regulations paired with ill-defined US Food and Drug Administration (FDA) guidelines on pharma in social media underscored the many challenges the industry faces when it comes to engaging with consumers online.

While the rule change is presumably intended to encourage the industry to engage in conversation with customers, resolve problems, improve products and forge relationships, it gives rise to a large number of issues. In addition to the traditional concerns that have fueled pharma's reluctance to embrace social media—including comments that provide misleading or inaccurate product information or promote off-label use—there's the unresolved issue of what to do about the reporting of adverse effects of drugs, which could land companies in trouble with government agencies.

But these challenges will not go away, however, given the increasing number of patients turning to social networking sites for health information. The National Research Corporation found in March that 16 per cent of the 23,000 U.S. citizens surveyed used social media as a resource for healthcare information. Nearly all of them — 94 per cent — reported Facebook as their site of choice, with YouTube coming in at a distant second at 32 per cent. Clearly, the industry does need an approach for participating in social media which yields a productive two-way conversation with consumers, whilst ensuring that risks are properly managed for the long-run. And for whoever chooses not to participate, someone will fill the void.

What pharma companies can do
The best way for pharmaceutical companies to approach this problem is with a mixture of rigour and openness. The systematic and business-like approach that goes into something like developing customer service processes at a call centre is entirely appropriate for Facebook, even if that might feel like it goes against the free-wheeling spirit of the medium. But being on Facebook does mean that pharma brands need to be tuned into the way consumers talk about their products, so that they can respond appropriately.

To alleviate healthcare companies' concerns of participating in Facebook, potential solutions include a customisable moderating application that allows a single administrator to track, log and action comments. This way, companies are in complete control of the content of their Page, allowing administrators to engage in meaningful dialogue with customers, while knowing they have a system to manage risk in place. A key to this is to be transparent about how the process works and why, so users can be informed of the legal issues that dictate the need for this communication process.

Customisable solutions
What this means is that companies need solutions that are customised to the way they work. For example, a large multinational's workflow system to manage and track Wall posts may need to be able to handle multi-lingual content or escalation processes for legal review. In addition, workflow-processes might need to be able to be integrated easily into existing systems to ensure seamless management of these pages, all dependent on the individual requirement.

The solution needs to be scalable enough to handle managing multiple pages at once, in addition to new Facebook Pages that are set up in the future. But that solution might be overkill for a company that is more decentralised in its approach or for brands where marketing abroad is done by others.

Another reason for a customised solution is that it needs to be malleable for future Facebook policy and regulatory changes. The moderation tool needs to allow for flexibility over time, as changes in individual companies and in Facebook are inevitable. If a pharma company can refine its Wall moderation system to adapt to these changes, they can rest assured that they're prepared for any hurdle social media might introduce.

And while the tools and processes need to be based on good process design, the approach to communicating with stakeholders on Facebook needs to be based on understanding the brand's audience and the unwritten rules of Facebook. Pharma companies' greatest fear when delving into social media is that users might post in a way that violates FDA rules and leaves them liable, or worse - that something unforeseen starts a firestorm they cannot control.

For many pharmaceutical companies, a Facebook app to facilitate content moderation might be the best solution regarding the August 15 rule-change, although the resolution will inevitably vary in its uniqueness to each firm. With any luck, armed with properly customisable tools and more concise guidelines from regulatory bodies, pharma companies will feel empowered to maintain a fruitful presence on social media platforms. 

Nils Mork-Ulnes - Beyond
The Author
Nils Mork-Ulnes
, head of analytics at the London-office of digital consultancy Beyond, developers of the PharModerator app for Facebook.

Twittertwitter.com/beyond

Facebookfacebook.com/beyondconsultancy



5th September 2011

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