Cullmann Design Blog

Last week, Tasigna, a Novartis product, received a letter from DDMAC for including a “share” button on their website. The letter stated that the utility “fails to communicate any risk information”. For those who may not know, a “share” button is a small widget that allows you to link to the site that it has been hosted on, with one or two clicks, to your favorite social networking service (Facebook, Twitter, LinkedIn, etc).

The issue with this tool (in order to make use of it) for the pharmaceutical industry, or any other highly regulated industry, is two-fold: 1.) There is a character limit placed on the title and description that is shown to other users using the framework provide by Facebook and 2.) That to be assured that this information is included in a social network post, it must be included in the metadata of the branded page (thus mitigating the natural search engine opportunity afforded by the use of metadata).

Controlling social media

The Facebook share widget, and almost all other widgets that are similar, use images found on the webpage they are linking to, any metadata (content coded into the page to help search engines) and the page title (again, content coded into the webpage for search engines) to create the presentation on the host service. Facebook is one service that provides these features. Just like search engine results that are shown to users when they make a web search, the amount of data that can be shown is limited. This is precisely the issue that the FDA has with the “Share” feature.

To add an additional complication, users can also make changes to the metadata before publishing it a part of their social network posting. Although there are many ways to do this using third-party solutions, the easy with which this can be done exacerbates the situation for brand managers and regulatory officials.

The “sharing” features of social media websites are a valuable tool for marketers and extend the reach of brand messaging. It makes use of peer-to-peer recommendations and allows easy communication of ideas and findings between professionals and patients alike. The relevance of social media for the Healthcare Professional can be debated, but regardless of your opinion, the ease of use and subtle differences between social media tools like this and search engine optimization (SEO) and search engine marketing (SEM) are indistinguishable.

Then what does this mean for SEO/SEM?

Recently, the requirements for presenting “important safety information” and warnings has become very important. Suggested parameters range from the vague “presentation above the fold”, to a persistent sidebar presentation,like Tasigna demonstrates, to a complete “opt-in” splash screen before beginning to display content. Regardless of your position, many of these parameters are moot when taking into account the growth of alternative consumption devices like mobile phones, iPads, and dedicated readers. The user experience is not nearly as controllable as regulatory groups would ideally be comfortable with.

I suspect that if regulatory boards and staff where more aware of how search engines worked and behaved that metadata too, would become equally as scrutinized. The limited amount of space allotted by search engines for description and the need to describe to doctors and consumers the offerings on a webpage may quickly come to odds. A danger exists in the sunsetting of branded pharmaceutical websites and the growth of less-accurate non-branded websites and third-party control of the search space for indication categories.

Is this preventable?

The facts around social media tools are that there is little anyone, brand managers, agencies or legal boards, can do to stop someone from linking to a pharmaceutical web property and manipulate the properties of a given post. What companies can do is pay attention to the attributes that these applications and services use. Do you know what the metadata on your brand’s websites says? Have you seen what it may look like if you link to it from Facebook or LinkedIn? That is the best place to start. You should include this in the discussion you have with your agency, peers and legal boards.

Educating yourself and those responsible for approving your web properties is more important than ever. The presentation of the DDMAC letter shows how the FDA is educating itself and taking a position. Marketers will need to be equally, if not more educated, in order to avoid the conditions which Tasigna must address.

What can be done?

If you are responsible or contribute to a brand that may require a black box warning or similar safety notification requirements, there are currently some limited actions that can be taken to make use of social media sharing tools:

• Check your metadata. Can you provide a description of your content and your required legal disclosure in 420 characters or less (you likely don’t work in pharmaceutical marketing!)? At the time of posting, that is the current maximum character count for Facebook’s status area. Anything additional will be truncated.
• Does your brand have a dedicated Healthcare Professional section? Although consumer facing communication is harshly regulated, the jury is still out on making a use-case for “sharing” tools to be a peer-to-peer vehicle with slightly more liberal policies for social marketing requirements.
• Do you have an unbranded channel? This would be an ideal opportunity for using Facebook, Twitter or any other social media channel as a driver and awareness vehicle.
• Talk to your medical legal review board. Nothing can aid your cause more than knowing your company’s policies and what your board’s opinions and policies are for the use of social media and how that may apply to a particular indication or brand.

NOTE: The opinions expressed in this and all of my posts are my own and are not those of my employer or its parent company.