Swiss drug maker Roche has moved to master the hazard-prone digital communications space with a new set of internal guidelines
on when, where, and how to apply social media tools to communicate with key stakeholders and the public. The initiative is
a novelty for Big Pharma—Roche says it is the first in the industry to go public with a transparent standard for online behavior—and
follows on the heels of written guidance issued by other corporate behemoths such as IBM, Wells Fargo, and Coca-Cola.
The 14 Social Media Principles (see chart) piggyback on Roche's existing group code of conduct and communications policy.
The guidance relies on simple "common sense" language, but carves new ground in making explicit the need to: 1) Differentiate
between using social media in a personal versus professional context; 2) Build clarity in speaking about the company and on
behalf of it, through third parties; and 3) Advocate for employees to serve as "scouts" in tapping networks to identify "sentiment
and critical issues."
Roche Social Media Principles
The 14 principles consist of brief bullet points and are divided into two sections of seven principles each, covering personal
and professional online activities.
The document has been welcomed—if not widely celebrated—by the digital pharma community as a good example of corporate transparency
and openness. Speaking on his STweM blog (
http://Stwem.com/) on Aug. 17, the day the guidelines were released, Andrew Spong, Editorial Director, Nexus, at the PSL Group, called it "trust
enabling," a "spur to ethical conduct," and heralding "a new era for healthcare communications."
Different Strokes For Different Folks
But for all their simplicity, clarity, and common sense, are the guidelines too general to be meaningful? The question is
important as it also goes to the heart of how legal approaches to the regulation of online communications differ between the
US and Europe. In the latter case, such information is subject to self-regulation, with the industry policing itself, while
in the US companies must take a far more cautious stance because the FDA is the ultimate arbiter of what companies and their
employees can or cannot say.
Where Roche can be said to be breaking new ground—and where it is also laying itself open to criticism—is in its attempt to
bring structure to the kind of ambivalent behavior that obscures the dividing line between personal and professional use of
social media. Coming from a US legal perspective, Arnie Friede of
http://FDALaw.com/, in an Aug. 17 post on the EyeOnFDA blog, noted the principles "suggest that employees can speak 'about Roche' in some kind
of 'personal capacity' ... without providing clear ground rules about the permissible content of these communications." He
adds that while the guidance document amounts to a "nice touch" from a PR/perception-of-transparency perspective, "absent
clear rules about what things may be discussed ... the new standards may create more problems than they solve."
Not surprisingly, Sabine Kostevc, Roche's head of Corporate Internet and Social Media, disagrees. She told Pharm Exec: "Before this set of guidelines, we had a very elaborate document with do's and don't's as well as many references to some
very detailed SOPs [standard operating procedures]. It is a key learning from that document that we needed a shorter and more
basic first reference that was not too long to scare people away from reading it at all."