The guidance urges people to “think before you post” and, if in doubt, not to post, like or share it at all.
Aimed at comms staff from pharma firms and the healthcare agencies they use, the guidance was drawn up by the HCA in consultation with the Compliance Hub, an agency that helps companies comply with pharmaceutical and med-tech codes of practice.
Pharma code breaches
There is a growing number of cases where pharma firms have fallen foul of the Association of British Pharmaceutical Industry’s UK Code of Practice over their use of social media.
Several breaches of the Code were published in 2019, involving multiple social-media platforms.
Every post that named or identified a prescription medicine was deemed to have been inappropriate.
In the first half of last year, the Prescription Medicines Code of Practice Authority (PMCPA), which administers the Code, found five cases where it had been breached due to social-media use.
There there were eight such cases in 2018.
The Panel considered that the lack of adequate UK specific social media guidance at the time of the complaint meant that Alexion had failed to maintain high standards and a breach of the Code was ruled.PMCPA report
In one case, Alexion was censured for a post on LinkedIn detailing how it had submitted an EU application for approval of a new treatment for patients with a rare blood disease (paroxysmal nocturnal hemoglobinuria).
The PMCPA report stated: “The Panel considered that the lack of adequate UK-specific social-media guidance at the time of the complaint meant that Alexion had failed to maintain high standards and a breach of the Code was ruled.”
The new HCA guidance warns that social media should be approached with caution, “otherwise it could place the pharmaceutical company at risk of breaching the UK Code of Practice”.
It adds: “As an employee of a pharmaceutical company, or as an individual working for one of their agencies, any social-media activity you undertake (inside or outside of work) relating to the pharmaceutical company, could bring that company in breach.”
Pharma's responsibility for suppliers
Pharma firms are accountable for the actions of both their employees and suppliers, according to the guidance. In the case of companies where the head office is overseas, the UK affiliate can be “held accountable” for the actions of the head office.
“It is not acceptable to promote a POM [prescription-only medicine] to the general public,” the guidance states.
This includes “proactively making an individual aware of a POM” and applies to anything placed online by “any UK-based element of a pharmaceutical company (or its agencies)”.
Information about prescription-only medicines, including press releases, clinical trial reports, or published news items, is “not suitable on social media” because such platforms are used to circulate and share content.
There should be “no posting, tweeting, retweeting, forwarding, sharing, messaging, liking, etc”, it says.
However, information about medical conditions can be shared on social media if it does not include the brand name or generic name of any medicine.
And it is acceptable to work with influencers on disease-awareness campaigns, as long as the company’s involvement is clearly stated, the guidance adds.
Mike Dixon, chief executive of the HCA, told PRWeek: “We are in a world where our employees are used to open communications via social media, where liking and reposting are natural responses to something they see and support. However, when it comes to pharmaceutical marketing, this can so easily lead to an inadvertent breach of the Code.”
And Steve Gray, managing director of Compliance Hub, commented: “It is important for organisations working within the pharma sector to ensure they give their employees clear guidance on their personal responsibilities in using social media with health-related content.”
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