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The pachyderm in the parlour: resisting the legitimation of DTC social media activities in Europe

Last week, my #hcsmeu co-founder and collaborator Silja Chouquet offered a great summary of some of the reasons why those who take an interest in health care in Europe must guard against modeling their own activities in 2010 along the lines of those that were undertaken at the FDA social media hearings in Washington last month.

I won’t repeat the post’s observations and conclusions here, but if you have yet to read it, please do so now. Silja, myself, and the Health Care Social Media Europe community will have a lot more to say about this in the months to come.

Instead, I will conjour up a symbolic pachyderm that may like nothing better than to settle itself in Europe’s parlour by asking a question that was not raised in Washington, namely: is it appropriate that pharma should be allowed to use direct to consumer (DTC) messaging within social media environments at all?

Regardless of whether they facilitate ‘1 click away’ access to fair balance and safety information, ‘improve’ patient safety through the use of a mooted adverse event reporting widget, or create a collaborative framework for patient interaction, from one perspective the FDA hearings were little more than an attempt to legitimate DTC advertising within social media environments without having debated whether they should be allowed to do so in the first place.

There is a fallacy of intention at the heart of the proposition that pharma marketers have a de facto right to conduct themselves within global social media environments in the same manner that they have traditionally done within broadcast media in the USA, and that the outcome of the FDA hearings must of necessity be viewed as a means of discerning how, rather than why, regional DTC marketing should be undertaken within the flourishing global patient and consumer communities that have been brought together by social media.

Would a ‘1 click’ rule help patients make better health decisions, or would it provide the pharma industry with better targeted advertising opportunities?

Would an adverse event reporting widget improve safety for patients, or would it reduce the risk of litigation for pharma?

Would a collaborative framework enhance intra-patient and/or patient-health care professional interaction, or would it afford pharma the opportunity to inveigle itself into a conversation it is danger of being shut out of?

The European pharmaceutical industry would probably also like to pass immediately into an arena wherein interminable discussions will be held as how it could conduct its marketing activities within social media without having first scrutinized whether it should be allowed to do so as a first principle. In order to prevent this conceptual segue taking place, I would favour coaxing our elephant from the parlour to the portico: from the space within which the debate is being held, to the entrance that it would symbolically block. At least we would then be able to have a discussion as to whether it should be allowed in through the front door rather than being shooed in through the back way.

Whilst there are any number of justifiable conversations and sanctionable interactions that the pharma industry could rightfully expect to be able to productively engage in within social media, DTC advertising is not one of them.

To my mind, DTC advertising has no place in European (and therefore by the necessity of extension, global) social media. It is critical that the global – not just American – patient communities who have been largely excluded from the debate until this point should be making their voices heard in this regard by contributing to the commentary that the FDA is currently collating, as well participating in the survey that John Mack is running.

7 thoughts on “The pachyderm in the parlour: resisting the legitimation of DTC social media activities in Europe

  1. I totally agree, Andrew. I don’t know if DTC advertising has proven any benefit in the US. From a European point of view, as long as it should not be a “consumer’s decision” kind of purchase but an informed medical prescription, I still don’t see the point.

  2. Hi Alain

    Thanks for your comment. With new times come new tools. With new tools come new expectations. It is not a given that DTC advertising has a right to exist within social media in the USA, regardless of how it is regulated.

    Social media creates conversation, builds trust, and facilitates interaction. It’s a relational space, not a transactional one. Pharma should look at the ways in which it can use social media to rebuild its shattered reputation rather than attempt to influence sales.

    Long-term advocacy is going to achieve a lot more than short-term sales campaigns. You can’t do both. In social media, there’s one shouldn’t even attempt if you want to be taken seriously.

  3. Great article, Andrew. Question for clarification: how do you define DTC?

    I have seen that it’s defined quite differently both in different countries and among people in the same company. To one, it might mean directly advertising a specific brand to a patient. To another, it might mean setting up a non-product-specific community. To a third, it might mean ANY communication with a patient, branded or unbranded.

    It’s a critical distinction, as people take sides on your very thought-provoking question. I’ll reserve my answer until I hear yours, so I can ensure I’m answering the right question.

    Thanks,
    JMR

    • Hi Jonathan

      Thank you for stopping by to leave a comment.

      The point you raise is absolutely germane to the consideration of this issue from a global perspective, namely: to what are we referring to when we talk of ‘DTC’?

      All three of the definitions you offer could be said to pertain.

      If you want specifics within the EU, you have to refer to the codes of practice for the promotion of medicine for the country in question. Links are collated on the EFPIA site:

      http://www.efpia.eu/Content/Default.asp?PageID=296

      That’s only the black and white, however; there are innumerable shades of grey.

      Where, for example, does this post on the UK ABPI’s site sit along this spectrum? (see the paragraph entitled ‘the Informed Patient Initiative’). Is it a guideline? Is it a comment?

      http://www.abpi.org.uk/publications/publication_details/expert_patient/power_point_otherInfo.asp

      Then there’s the Danish journalist who probably thought his blogging in no way, shape or form resembled DTC advertising. Unfortunately for him, the Danish judicial system thought it did:

      http://www.burrillreport.com/article-1381.html

      What can we conclude from the above?

      I think we have to begin by conceding that ‘DTC’ means something different just about everywhere. To me, it is conclusive evidence that the EU can’t just look to America for the FDA’s forthcoming guidance when it comes to consider its own stance(s). It has to make up its own mind(s).

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