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A role on the council

Just who can lay claim to what when it comes to new-age communications?

Cartoon businessmen standing on top of each other in a pyramid formationThe role of digital and social media in healthcare marketing and communications is evolving rapidly. With the advent of self-publishing technologies and the expansion of mobile connectivity, digital and social media have empowered the masses to communicate around the globe within seconds. Healthcare providers, patients, caregivers, advocacy groups, pharmaceutical, biotech and medical device companies have become increasingly active in emerging digital channels such as social networks, online communities, blogs and various audio and video sharing sites.

As a result of this transformation PR, marketing, corporate communication and public affairs roles are beginning to blur. This changing landscape means that roles, responsibilities and accountability need to be redefined. To achieve a viable working model moving forward, companies need a framework for communicating in the digital age, from establishing guidance and educating employees to assigning responsibilities and addressing legal issues. 

Creating a council
The first challenge in developing guidance and evolving current policies for digital and social media programming is determining who will play the role of 'go to' person in the PR, marketing and corporate communications departments. The go to person will help define ownership when communicating in the digital channels. Once this role is identified, there should be agreement on the digital landscape so that when programmes are presented to the legal department there is consistency in how each communications and marketing discipline will work within Prescription Medicines Code of Practice Authority (PMCPA) regulatory guidelines.

Some companies have created internal councils to achieve this consensus. These councils address questions regarding digital and social media activities and often include key representatives from regulatory, legal, safety, marketing and corporate relations to develop standard operating procedures (SOPs) and policies.

Council meetings are usually the first opportunity for each department representative to learn what others are doing. More often than not, companies as a whole are doing more than they would have anticipated, be it internal (such as creating internal Wikis or social networks) or external (for example, podcasting, outreach to digital media influencers or launching social network pages).

Having a clear picture of what digital initiatives are taking place within the company can help shape the council's perspective on policies and procedures, especially if legal or regulatory have already approved some programmes.

Who owns what?
It's easy to be bewildered by the many (and often apparently overlapping) terms used in the online world, such as 'social media', 'digital media', 'Web 2.0' and 'social networking'. It would be great if there was one term that could extend the current definition of 'online' or 'interactive' communications, such as 'new media', but that doesn't help to clarify who owns what and what the barriers are from a regulatory standpoint. For example, does e-marketing own all 'online' or do PR and corporate communications also have a responsibility? What are the legal and regulatory guidelines for each?

Here's a general example of how to define digital and social media. Digital media influencers fall into five categories: blogs and online news (such as; search and reference (Google, Wikipedia, Yahoo!); online communities (Sermo,, iVillage); social networks (Facebook, YouTube, flickr), and mobile (iPhone).

Social media applications too fall into five categories: widgets; syndication and micro blogging (RSS); ranking (recommendations, comments, active tags); mash ups, chat and networking, and audio, video and images (slideshare).

Digital and social media don't fit neatly into one discipline, and this has proved to be a roadblock for many companies. Is it PR/corporate communications, marketing, advertising, customer service or IT? In some organisations, everyone is doing it, and there is no integrated strategy. In other organisations, no one is doing it, because of perceived 'legal' ramifications or lack of clarity as to who is responsible. Additionally, many companies that are ready to get started still struggle with fundamental resource issues, such as sufficient head count and the right kind of employees to drive social media programmes and the appropriate role for agency partners.

A council can help to reorganise and align internal disciplines to implement digital and social media programmes successfully. In general, PR, corporate communications and public affairs professionals are responsible for building relationships with digital media influencers and may engage with these influencers on a wide range of tasks — for example, to: correct inaccurate information; generate awareness; build community; increase thought leadership; prepare for a crisis, and communicate news that will result in earned media placements.

Marketing professionals are creating content using social media applications for the purpose of brand or company communications, targeting and aggregating key audiences around a brand or disease awareness. This activity is usually done through paid media and requires a greater level of regulatory scrutiny.

Policies and procedures
Once the landscape is defined, the council will evaluate, update or create policies and procedures and disseminate insights to each of the brand's communications groups (PR, branding, online marketing and so on). Understanding official corporate digital and social media policies will help the review process for any new programme.

Below are several US examples:
•   Adverse events — The number one concern among pharma companies involves the complexities involved with discovering adverse events (AEs) and reporting them to the US Food and Drug Administration (FDA). There are many tools and methodologies for monitoring digital channels, but the majority of AEs discovered online do not meet the FDA's criteria for a 'reportable adverse event', which include: an identifiable reporter; an identifiable patient; an identifiable drug, and an identifiable adverse event. The reality is that most pharma companies are monitoring digital channels for market intelligence, issues management and media relations, rather than AE reporting, purposes.
•   Fair balance — The FDA has established clear guidance for direct to consumer (DTC) promotion and for applying fair balance to marketing and advertising programmes to ensure the public receives information about a drug's safety and efficacy profile and not off-label uses. Even non-branded activities could easily be perceived as branded by the FDA, especially if the drug is the only one on the market.
•   Privacy — Fair balance and AEs are often the first roadblocks to digital health initiatives, but privacy is actually a bigger concern. Many PR and marketing professionals, as well as consumers, ignore the terms and conditions of a public website. More often than not, those terms state clearly that manufacturers are not allowed to engage in community forums, chats or discussion boards. But what about monitoring? Patient privacy is less of an issue if the site is a public forum where members provide their private information voluntarily, but on closed or password-protected sites it is paramount.
•   Trademark and copyright protection — This is one of the most basic legal issues associated with online content, but the ownership of consumer-generated media is often unclear or disregarded. The definition of what exactly 'fair use' means is hotly debated and remains a poignant issue in a digital age where takedown notices and copyright infringement may discourage creativity. When using existing online content, there are rules that companies must adhere to as per Fair Use legislation and other copyright statutes, but trademarks and copyright on images, photos, music and art must be licensed or pre-authorised by the site owner.
•   Transparency — Many companies have attempted stealth marketing in the past and have been caught out. Stealth marketing practices are those designed to deceive people about the involvement of marketers via online communication and might include paying key opinion leaders or patient advocates to promote therapies online without disclosing that they have been asked to represent the company, using fake identities to impersonate consumers, posting information on blogs and message boards anonymously, disobeying rules established by individual communities, spam link-building and so on. Aspects of transparent communications to be incorporated into online activities include: clearly identifying who you represent; being truthful and non-misleading, and responding based on factual data or an established point of view consistent with approved labelling.

Ongoing participation
While establishing policies and procedures is critical to the success of pharma companies moving forward, it is equally important for a council to meet on a regular basis (monthly or quarterly) to re-evaluate the current environment and determine if policy and procedure updates are needed. These ongoing meetings will also provide the council with the opportunity to review newly developed and implemented initiatives related to digital and social media communications. This allows all council members and their respective departments to be aware of what others in the company are doing.

Continued participation by the council in managing digital and social media policies and procedures will help ensure both that the company has its finger on the pulse of the rapidly evolving digital and social media environment, and that it is potentially ahead of its competition regarding how it manages communications efforts in this space.

Similarly, the US Federal Healthcare Reform Law includes 'Sunshine Reporting Provisions' which apply to payments or gifts to physicians valued over $10. Reports are due in March 2013: it will be interesting to see how lessons learned at state level — and communications challenges, perhaps even scandals — will be reconciled on a national scale and potentially even adapted internationally later on. At issue are once-common business relationships that will now face close scrutiny.

With all these initiatives, medtech companies will need to be prepared with communications strategies focused on growth drivers as well as being armed with strong messaging against potential business problems should there be pitfalls lying ahead.

The Authors
The Cohn & Wolfe digital team

To comment on this article, email

22nd September 2010


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