Setting a Bad Example

Pharma's problem with listening is that it means letting people talk first, and this is where much of pharma's fear of social media lies. The calls for pharma to quit using social media tend to rest heavily on a few well-rehearsed horror stories involving damaging public comments. One of the best known is the case of the VOICES Facebook page set up by Sanofi Aventis to "empower" employees, friends, families, and communities but hijacked by disgruntled users of its drug Taxotere.

Alongside an unflattering picture of a balding head, one visitor to the VOICES wall wrote: "This is my disfigurement from your drug Taxotere, the drug [where] you kept this adverse side effect secret. Why don't you want to answer my letters and e-mails?"

It's tough to see what Sanofi could have done to avoid such a determined assault, but a clear—and clearly visible—Terms of Use policy would have made it easier to deal with. Sanofi's corporate communications department was later obliged to make the Terms of Use more conspicuous on the VOICES page, commenting: "Because social media is evolving at a rapid rate, the company continues to refine our extensive guidelines regarding how to address dialogue about our company on social media sites such as Facebook and Twitter."

There was also the case of Procter & Gamble's Asacol Community site for ulcerative colitis (UC) patients. The Community offered a forum for patients to share their stories of the condition, and guidelines were put in place that deemed that Asacol or other drug treatment options could not be mentioned by name. The content was moderated, but consumers could, it was claimed, rate and vote on story content and answers.

The 'moderated chat,' however, was somewhat too moderated. Comments could not be submitted in response to a story, 'votes' did not appear to be counted, and it could take up to "three business days" to see a user comment posted. After asserting that "most consumers never read guidelines or Terms and Conditions as carefully as I do," PharmaGuy noted in a 2009 blog post, he concluded that the "Asacol Community is NOT a real community and NOT a real chat."

In addition to Facebook, pharma has also run into trouble with YouTube and Twitter. FDA served Warner Chilcott with a warning letter in May for a video posted to YouTube starring one of their sales reps. The video was posted by the rep "under the direction of a Warner Chilcott district manager," according to the letter. The video misbranded the drug Atelvia and made unsubstantiated claims about the drug and dosage, omitted risk information, and so on. In the UK, on Twitter, Bayer ran afoul of the Prescription Medicines Code of Practice Authority's Code of Conduct, after several tweets promoting Levitra and Sativex went out to consumers, which is of course illegal in the UK. The tweets were accused of not presenting risk information appropriately.

Taking Control

The first of the Big Pharmas to take the plunge and establish–in the absence of direction from the regulators–some internal guidelines for using social media was Roche. In August 2010 the Swiss drugmaker went public with a transparent standard for online behavior (see Pharm Exec, October 2010).

Roche came up with 14 Social Media Principles that made explicit the need to: 1) differentiate between using social media in a personal versus professional contexts; 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."

The move was broadly welcomed by digital pharma commentators, with Andrew Spong calling it "trust-enabling," a "spur to ethical conduct," and heralding "a new era for healthcare communications." But it was not without some controversy. By trying to bring structure to the kind of ambivalent behavior that obscures the dividing line between personal and professional use of social media, the company was also inviting criticism for fusing the personal and professional and, at worst, creating an environment that smacked of Big Brother in its monitoring of staff social media use.

Sabine Kostevc, Roche's head of corporate Internet and social media, responded to Pharm Exec saying, "It is a fact of life that people will always discuss topics or issues around us—online and offline—and nobody is in a position to prevent this. We can only try to make sure that it happens in a responsible way where our employees are involved. We merely wanted to offer guidance on where to go if colleagues come across any issues. Apart from that, all employees are educated and required to report adverse event information that they encounter, [regardless of the] communication channel."

3rd Annual Life Sciences Forum on Social Media Regulations and Compliance

Leverage Digital Networks while Ensuring Promotional Compliance

June 19-20, 2012
Alexandria, Virginia