Visionary companies across the business spectrum are reaching out to consumers through official, corporate-authored blogs.
It's a fast, inexpensive way to bring the brand message to tech-savvy customers around the world. Blogging is an easy marketing
method for any industry—except, of course, for pharma, which has to contend with a veritable minefield of potential blog-related
Fundamentally, blogs represent the most extreme form of unregulated communication available—a style of unchecked discourse
that flies square in the face of how pharmaceutical companies have been structured to behave and communicate. This structure
is borne from a need to comply with strict government regulations that exist to ensure that pharmaceutical companies promote
their approved products in an appropriate and responsible manner in order to ensure the public's health and safety. To date,
FDA has yet to issue guidelines that specifically address how companies should communicate on the Internet. The agency has,
however, stated that online communication should be governed by the same principles that apply to television and print advertising.
This guidance was adequate back when a Web strategy consisted of a product Web site that was little more than an online brochure.
However, the new generation of Web services has created an whole new set of challenges for the pharmaceutical industry—an
industry that, like most others, is keenly interested in listening to, communicating with, and engaging its customers.
The primary challenge for pharma in this arena is the concern that a commenter may mention an adverse event on a company-owned
blog. If that were to occur, the company would be required by FDA to report the event. Reporting an adverse event requires
"an identifiable patient," but since most comments tend to be posted anonymously, this presents the first of many problems.
Capturing significant information about a person raises questions of patient privacy. When an individual discloses his/her
health condition on a blog, it is now public—and if the blog is owned by a pharmaceutical company, that company could be accused
of violating an individual's privacy simply for having facilitated the disclosure.
Because the company is ultimately responsible for all blog posts and comments, it should take care to implement safeguards.
All submissions absolutely must be reviewed by the company's internal medical, legal, and regulatory teams prior to publication.
Unfortunately, an internal review process may take days or even weeks, detracting from one of the most appealing factors of
a blog—the freewheeling, ongoing dialogues and debates that people have come to expect from this medium. The lengthy lag time
between comment submissions and public postings, coupled with the restrictive rules on what can and can't be posted, will
certainly make a pharmaceutical-sponsored blog a difficult enterprise to launch and maintain successfully.
Many complicated issues surround pharmaceutical-owned blogs, so it's easy to understand why most companies have not launched
blogs where people are allowed to post and comment freely. However, that doesn't mean pharma should give up on blogs altogether.
Planning for "The Event"
There's no need to reinvent the self-protection wheel. Pharmaceutical companies already have processes and procedures in place
for dealing with adverse event reporting through toll-free numbers and such Web sites as FDA's own MedWatch (http://
http://www.fda.gov/medwatch/). Here are a few tips for how to create a positive user experience while limiting exposure.
Communicate rules With any feedback form, provide users with very clear "rules of conduct" that explain what they can and cannot say in a post.
Apply filters Wherever a user is presented with an open-text form, implement filters that scan the specific terms or phrases that are being
keyed in and trigger an immediate "cannot accept this message" warning that explains to the user in clear language why this
information is not allowed on the site.