Medico Digital Insights

PMCPA’s Social Media Guidance: Navigating the Boundaries of Pharmaceutical Marketing

Compliance | Healthcare marketing | Social media

Read time

5 min

When

6th April 2023

Who

Written by Pippa Short

About

Advertising
Regulations

The 2023 guidance doesn’t offer a wealth of new information, but instead doubles down on the safe and cautious approach all relevant bodies would like to see pharmaceutical companies take with respect to social media. While much is discussed about the restrictive nature of these guidelines, we continue to see huge opportunity in the patient education space and would encourage others in the conscious pursuit of better healthcare communication that’s beneficial for pharma, HCPs and most importantly patients.

Earlier this year the PMCPA (Prescription Medicines Code of Practice Authority) released new social media guidance for the pharmaceutical industry to help give some clarity on what has historically been a very grey area (for anyone that’s still confused, check out our guide to the EU MDR laws here). The guidance has been designed to give more clarity on how social media can be utilised as a platform in the industry, and to ensure that any promotion of prescription medicine complies with the Association of the British Pharmaceutical Industry’s (ABPI) Code of Practice.

This guidance comes in response to the rapidly changing landscape of social media and the need for the pharmaceutical industry to keep up with the latest innovations whilst ensuring they are not in breach of the ABPI code. The document provides a foundation for companies to use to ensure that they are communicating with patients and healthcare professionals responsibly in an informative and transparent way that does not directly promote prescription medicines to the public. Although the guidance does not offer explicitly granular advice, due to the nature of the PMCPA taking a case by case approach, it does align with EFPIA and IFPMA’s published guidelines on social media and digital channels and is very much welcomed in the industry.

Below is a summary of some of the key principles from the document for you to digest. 

Transparency in pharmaceutical social media marketing

One of the key principles in the document is the need for transparency and that pharmaceutical companies should always be transparent in all aspects of their communication. All content posted on social media, including from third parties, should clearly define that company’s involvement. This is particularly important when companies decide to work with social media influencers, any relationship must be clearly stated from the outset and in certain cases the company may be liable for the content posted by the influencer. 

Marketing pharmaceuticals on social media responsibly

Not only is transparency crucial, it is also important pharmaceutical companies take responsibility for any social media activity carried out by a third party or an employee/affiliate. If for example content is posted, shared or ‘liked’ by a UK company and its employees or any activity promoted by affiliates, it comes under the scope of the UK code.

Use of Social media for Adverse Events and Pharmacovigilance 

Another area of focus for the guidance is the handling of adverse event reporting and pharmacovigilance. It notes that companies should ensure social media platform monitoring is in place and that it is made clear to users where they can report adverse events. 

Pharma Product References and Pipeline on Social Media

Unsurprisingly, the guidance reinforces the explicit prohibition of the promotion of prescription-only medicines (POMs) to the public and reflects EFPIA’s guidance that any mention of POMs is likely to be considered a promotion. The document also highlights that even if a product is promoted on social media without being named but references its indication, this is seen to be presumptively promotional and could be in breach of the ABPI code. 

Significantly, it is recognised that companies are often turning to social media to attract the corporate community and share product pipelines. In this instance the guidance gives safeguards to consider when companies are looking to share press releases which may include unlicensed medicine, and even gives this example:

‘An informative statement shared via a corporate public LinkedIn account which is linked to a press release within the media section on the corporate website about recently published results for an unlicensed medicine. The statement on LinkedIn should not mention product name or study name, but should clearly signpost the intended audience, for example, ‘For Investors’ or ‘For Medical Media’ and might state ‘new press release regarding recently published data in Oncology is available on our website [link to media section of corporate website].’ 

Pharmaceuticals use of social media for Patient engagement 

As social media is now regularly being used as a channel to engage with patients, the guidance recognises that companies can use it as a platform to share non-promotional information, with the aim of increasing disease awareness and educating patients, parents or caregivers. The document also mentions the use of platforms such as YouTube, which can be used to host POM informational videos so long as they are hosted on secured, non-public URLs and the audience is clearly identified and content is appropriate. 

Pharma links, hashtags and tagging on social media

These topics tie in closely with the importance of transparency. The guidance explains that companies should be cautious when using links as they are responsible for any content shared, meaning the content should be checked and approved to ensure it’s appropriate. Tagging and hashtags add yet another layer of risk as, although they can help users navigate topics, they may inadvertently lead to product claims and a breach of the ABPI code.

To summarise, the use of social media does raise particular challenges for the industry as it’s difficult to guarantee the intended audience and all communication is subject to the traditional forms of UK advertising regulations and the ABPI code. However, this new guidance does shed light on many aspects of social media usage and is a very welcomed document. As ever, it’s critical companies adhere to local guidelines and provide training to its employees on the use of social media. Creating your own company guidelines helps employees manage the ever changing landscape of social media and digital marketing.

For more information on pharmaceutical marketing, give us a call today to chat further. Additionally, you might find these posts interesting:

How can Medico transform your healthcare business?

I need help with
cloud
Deep understanding of the healthcare market
data
Access to vast amount of data
squared_man
Detailed patient personas

FREE guide: The 6 most common healthcare marketing mistakes and how to avoid them

Medico DigitalExcellentMedico Digital4.9 Based on 51 reviews fromSee all reviewsMaria Zaleska ★★★★★ Medico have been a pleasure to work with. Their digital expertise and sector knowledge enable them to be agile and complete projects efficiently and on a budget, in a way that I haven’t experienced from other med-comm agencies. They provide great advice and strategy that I would highly recommend if you’re looking for a healthcare marketing agency that can truly deliver on your digital objectives. Maria@NevroResponse from the ownerThanks Maria, this means a lot! It was a fantastic project to work on, hugely strengthened by your in-depth knowledge and ability to communicate and help us understand the HCP and patient journey for this truly innovative treatment. Really looking forward to continuing our relationship. Wayne Allison ★★★★★ The team at Medico have always provided top quality digital support, often going above and beyond for our UK team.Response from the ownerThanks so much for your review Wayne, much appreciated! Ilaria DE GIOVANNI ★★★★★ The team at Medico have been brilliant at working with our MLR team to get content approved, going above and beyond with sourcing and research. As well as the medical accuracy, the content is always really high-quality and readily optimised. Would definitely recommend them!Jim miller ★★★★★ Medico have been an excellent company to work with. They are always quick to respond to requests, understand difficult issues and ensure that the outcome is what we've been looking for.Ben Eddy ★★★★★ We have used medico Digital for my personal website, they have provided an excellent service, particularly when it comes to editing and refining the site so make it work and function properly. They have an attention detail and its been excellent working with them. I have used jack Lewis to build my site and he has created an excellent and professional looking site. Many thanks Medico Digital.Liz Marshall ★★★★★ Hi, Medico digital built our website and we are delighted with it, nothing was too much trouble and the after sales is also great we still have few areas to add which we as a company are working on ready for Jack to complete the project. I would recommend Medico DigitalMazin KC (KC Mazin) ★★★★★ Had a great collaboration with Medico Digital. Efficiently scaled the business and achieved the goal.Response from the ownerThanks Mazin, it was a pleasure working with you and the VPS team. Adam Harding ★★★★★ Fantastic team who deliver a great service and product. Very responsive. Overall a great experience.Digitaldrop Solutions ★★★★★ Best Digital Marketing services at affordable prices range and Team Response was Very GoodJosephine Trotter ★★★★★ Medico Digital are a fabulous agency with an impeccable standard of service. The team are friendly, professional, quick to respond, and solution focused. They oversee both our websites, our SEO strategy, and our PPP objectives. Most recently they managed the migration of our websites to WordPress and this project crossed the line on-time and without a single hitch, we felt we were in safe hands at all times. We are delighted to be working with them and would highly recommend them to anyone who strives for the best!Joshua Harwood ★★★★★ Jack and the team were excellent throughout. Medico Digital were more expensive than I originally intended for my website but I really don't regret paying extra. They made me a great website, were responsive throughout the process and guided me through it. Since launch they have continued to support me to figure out how the whole thing works. I could have used a little more guidance on what I need to do after launch (e.g. maintenance, google analytics etc) as certain things were set up without telling me and I did not know about it, but that is not enough of a concern to warrant losing a star and every time I ask they come back and help very quickly. Overall very good service, I would recommend.Jonathan Gill ★★★★★ The whole team have been exceptional in developing and managing my private practice website which significantly increased the number of patients that I see.ENT Sheffield ★★★★★ Beth Soanes and her team are a pleasure to work with and great help to my practice.shyam menon ★★★★★ It was a pleasure working with Jack. His advice and expertise enabled a very smooth and professional experience.js_loader