As far back as 728, August 15 has marked a turning point in history, from the founding of Paraguay in 1537 to The Beatles playing to a crowd of 60,000 at the Shea Stadium New York and the Big Ear radio telescope receiving a radio signal from deep space. This year, changes to the social media environment from August 15 will fundamentally alter the way in which pharmaceutical, biotech and medical device companies interact with consumers on Facebook. These changes are not based on new communications strategies or industry regulations, but come as a result of Facebook changing its policies; terms and conditions that dictate that the industry will no longer be able to prevent followers from posting on its pages.
No longer can the industry utilise Facebook simply as a 'broadcast' channel for corporate and disease messages; instead it must either interact or withdraw from the platform completely. So, just how should pharma respond to these changes and how does this affect the overall social media approach and profile?
A question of social openness
On May 17, healthcare company users of Facebook were emailed about policy changes directly affecting how the industry engages in this social networking service. Essentially, Facebook would no longer allow the industry to disable the capability for followers to post comments on their pages. These changes came into effect for new pages in June and will affect existing pages from August 15. Some exemptions to healthcare pages do remain, however; for example, those that name prescription drugs or devices, and/or those that include prescribing information on the page will still blocked. However, outside of the US, most healthcare company supported pages can't name prescription drugs/ devices or include PI - so are not exempt.
According to Facebook, these policy changes “support consistency for the Facebook Pages product and encourage an authentic dialogue between people and business on Facebook”. Facebook's mantra of social openness has been evident from the start, so in some ways this change should have been expected. “We also understand that these changes may lead you to re-evaluate your strategy and presence on Facebook. We are committed to helping you during this transition,” Facebook stated in its email. Yet this change, arguably, could have more impact than any of the long-awaited new FDA digital engagement guidelines.
It's difficult to assess exactly how many companies and Facebook pages will be directly affected by this change, as the exact number of pages produced or supported by the healthcare industry is unknown (although several leading companies have more than 30 pages globally each). Nonetheless, the initial reaction by many in the industry is one of concern. In fact, the reaction of many industry leaders with current Facebook pages –particularly those with fewer followers – may be to remove their pages. This may be simpler and more effective than trying to find a solution and address any legal, regulatory and staffing moderation requirements.
The need to report adverse events related to drugs and devices; the potential inclusion of inaccurate or off-label information; and posts from animal rights and environmentalist protesters are all potential risks that will need to be handled in the new Facebook paradigm. Furthermore, the question on whether and how to respond to comments, whether positive or negative, further complicates interactions.
Finding the right solution
The solution would seem to be some form of Facebook moderation system, combining a level of automatic and manual monitoring. A number of suppliers have developed several off-the-shelf solutions and a number of industry sponsors are in the process of selecting and implementing these. These options include automatically blocking certain comments and notifying an administrator of suspect ones; automatically deleting any comments as soon as they appear; hiring (or outsourcing) someone to live manual moderation; and real-time moderation via a 'custom' wall. The concept of a custom wall is perhaps the most attractive of these options. Without going into the technical details, this application is added onto the Facebook page – effectively mimicking that of the Facebook Wall, but allowing the page-owner to filter who can 'like' their page (essentially, who can add comments) and putting comments into a holding zone while they are moderated.
Yet all of these options still offer challenges:
• Firstly, they largely remain unproven. Most of these quite technical solutions have been developed only in the last few months. We have reviewed and identified some technical questions with all of these options. The custom wall, for example doesn't turn off the Facebook Wall – so all content must be removed from there and the ability to add new comment conversations turned off; otherwise, users could just comment on the Facebook Wall instead. Also, any user still has the option to comment on the profile picture – a function that cannot currently possible to disable
• Secondly, many of these options change the user experience away from that typical for Facebook
• Thirdly, all of the options we've seen still require significant manual moderation: translation, review and approval in a timely manner for potentially 30+ pages is no small task
• Lastly, Facebook is continually developing its products and services, so further changes are not only possible but also should be expected. For example, just a couple of weeks ago, Facebook introduced a new 'preview' function. Here website links included in comments are previewed directly on the Facebook page, before the page-holder can review it. Any moderator would then need to review the website link as well as actual comment.
Defining social engagement in the new world
Clearly, no option can offer the perfect solution and whatever happens a significant revision of industry social media policies are needed. While the industry adapts to this evolving environment, the question remains – what is the industry's longer-term strategy for the world of social media and can the industry have the two-way conversation with the public that this channel so eloquently delivers? Or are the risks to its reputation and current regulations to really engage with consumers in 'real' time?
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