DTCA/I, consumer secondary audience

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DTCi piece that include controlled substances
• Username

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Hello @Username

If the piece is truly DTCi, than yes, it would be acceptable to have mention of controlled substances. As the risks are higher with controlled substances, it is highly important to ensure that the piece truly meets the DTCi regulations and is not advertising.
722 - Understanding that Help-Seeking messages can not include the sponsor, what if a message was broad enough not to allude to a single product? eg. “Ask your doctor about CV medications from Company-X”.
• Jennifer Carroll

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749 - We would like to disseminate a branded dosing app to HCPs via the Apple/Google stores. Since app stores are open to the public, is this possible if (A) the app description/screenshots are limited to name-only and (B) the app reviews are disabled? The app itself would be password protected, so could only be opened by HCPs (consumers could download the app but not open it).
• Jennifer Carroll

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747 - Can branded DTC advertising include a claim of 'new' or 'now available'?
• Jennifer Carroll

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137 - Would there be an issue with an online banner ad that is exempt from PAAB review linking through to a PDF of the products' Product Monograph?
• Jennifer Carroll

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@NatBourre Good catch. The hyperlink was an error. We have revised the content now. Thank you.
690 - On what basis (code?) should a DTC magazine ad be prepared for a nonprescription drug product that is sold to the general public with the intervention of a healthcare professional ("ethical" drugs)? Secondly, should such DTC material be reviewed by PAAB or or by Ad Standard Council of Canada?
• Jennifer Carroll

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683 - Hi Patrick I've been told that vaccines fall under different promotional guidelines than other prescription medicines. We are putting together a now available pharmacy fax for our soon to be promoted vaccine and wanted to confirm if we need PAAB approval on this or not. The communication would include the brand name, logo, indication, price, DIN and product number. It would also include corporate trademarks. Thanks
• Jennifer Carroll

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657 - I'm working on building an app for a pharma client. It's a companion for a drug they market. But I'm concerned that the review section in the App Store will put us at risk of being non-compliant. Do you have any suggestions to help?
• Jennifer Carroll

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656 - In a DTC Consumer Brochure discussing treatment options for a given disease, can narcotic treatments be included in a balanced list of treatment options? We are assuming a Consumer Brochure is not defined as advertising under the Narcotic Control Regulations s70.
• Jennifer Carroll

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649 - Our company has an unbranded disease-focused app in the Apple/Google stores. As legally required, the manufacturers name must be disclosed in these stores. Can we make mention of this app in a separate DTCi Help-Seeking campaign (that itself does not mention the sponsor)? The campaign would not focus on the app, but mention it as one of many additional resources.
• Jennifer Carroll

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646 - I recognize that consumer help seeking campaigns cannot disclose the manufacturer's name. In the event of a DTC disease awareness website, that is seeking to allow users to opt in to receive future communications (all unbranded, disease related in nature), we're challenged by CASL regulations which appear to conflict with Health Canada's guidance. CASL regulations indicate the name of the sender must be included. If the sender of the communication is indeed the manufacturer, is the manufacturer's name, allowed for inclusion in the website copy in this circumstance, presumably with minimal prominence in order to solely meet CASL guidance? Or, can you provide examples, guidance, or a recommendation on how a manufacturer may meet CASL and Health Canada guidance in this situation? Thank you.
• Jennifer Carroll

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645 - Hello PAAB! Can sales representatives distribute a tool that was approved by PAAB as DTC to physicians to provide to potential patients? Would this tool need to be re-submitted through PAAB as unbranded patient material? Thank you!
• Jennifer Carroll

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643 - If a DTCI Consumer Brochure closes with a 'help-seeking' message, would it still be considered a Consumer Brochure, or would it be reviewed as a Help-Seeking Announcement (or a combination of the two)?
• Jennifer Carroll

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641 - Hi PAAB. Can you advertise a drug to the general public if it is indicated for a condition/disease not listed in schedule A.
• Jennifer Carroll

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637 - We are currently embarking on a help seeking announcement for a prescription product. The help seeking message will follow the criteria as outlined in Health Canada's policy, The Distinction Between Advertising and Other Activities. We wish to additionally inform HCP’s of this campaign through promotional systems such as a detail aid to ensure full transparency to the HCP regarding the campaign. • Are we able to identify the help seeking campaign in promotional systems directed to HCPS? • Are we able to include additional promotional product messages in the promotional material? • If not permissible in the same promotional system, are the two allowed in the same sales call?
• Jennifer Carroll

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634 - Hi PAAB, If a pharma company who markets a vaccine sponsors a 3rd party vendor for the writing of an independently written article on adult vaccines in which all treatments are discussed and this vendor distributes this article to HCP through their channels is this considered advertising and would the article require PAAB review? The Pharma company would not review the article. If the distribution by the vendor is to consumers does it require pre-clearance by PAAB? Could the sponsorship be identified at the article “This independently written article was sponsored by XYZ Pharma Co”? Given that the topic is vaccination and it is Schedule D, could we link an ASC approved ad with the consumer article as you mention in Question 153? Would this PAAB require pre-clearance? Thank you.
• Jennifer Carroll

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612 - In the context of a Consumer Brochure, is it permissible to provide DINs for a balanced list of medication options?
• Jennifer Carroll

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609 - Hello. Can a pharmaceutical company post a tweet on its Twitter platform about its product winning a research/innovation prize? For example, "Congratulations to Product X for winning the 2017 YZ Prize!"
• Jennifer Carroll

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607 - Does a HCP-directed website for a Schedule D vaccine need to be gated?
• Jennifer Carroll

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605 - Hi, We are a health clinic interested in running a publicly funded flu shot campaign for the public. We want have free coffee cards and lollipops to give to anyone who comes in and gets a flu shot. Are we allowed to advertise in a flyer and emails to the neighbourhood businesses specifying that anyone who comes in and gets a flu shot will get a lollipop ad free coffee cards? What are the regulations surrounding advertising our flu shot clinic? Thanks!
• Jennifer Carroll

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DTCi piece that include controlled substances • Username

722 - Understanding that Help-Seeking messages can not include the sponsor, what if a message was broad enough not to allude to a single product? eg. “Ask your doctor about CV medications from Company-X”. • Jennifer Carroll

747 - Can branded DTC advertising include a claim of 'new' or 'now available'? • Jennifer Carroll

137 - Would there be an issue with an online banner ad that is exempt from PAAB review linking through to a PDF of the products' Product Monograph? • Jennifer Carroll

657 - I'm working on building an app for a pharma client. It's a companion for a drug they market. But I'm concerned that the review section in the App Store will put us at risk of being non-compliant. Do you have any suggestions to help? • Jennifer Carroll

656 - In a DTC Consumer Brochure discussing treatment options for a given disease, can narcotic treatments be included in a balanced list of treatment options? We are assuming a Consumer Brochure is not defined as advertising under the Narcotic Control Regulations s70. • Jennifer Carroll

645 - Hello PAAB! Can sales representatives distribute a tool that was approved by PAAB as DTC to physicians to provide to potential patients? Would this tool need to be re-submitted through PAAB as unbranded patient material? Thank you! • Jennifer Carroll

643 - If a DTCI Consumer Brochure closes with a 'help-seeking' message, would it still be considered a Consumer Brochure, or would it be reviewed as a Help-Seeking Announcement (or a combination of the two)? • Jennifer Carroll

641 - Hi PAAB. Can you advertise a drug to the general public if it is indicated for a condition/disease not listed in schedule A. • Jennifer Carroll

612 - In the context of a Consumer Brochure, is it permissible to provide DINs for a balanced list of medication options? • Jennifer Carroll

609 - Hello. Can a pharmaceutical company post a tweet on its Twitter platform about its product winning a research/innovation prize? For example, "Congratulations to Product X for winning the 2017 YZ Prize!" • Jennifer Carroll

607 - Does a HCP-directed website for a Schedule D vaccine need to be gated? • Jennifer Carroll

DTCi piece that include controlled substances
• Username

722 - Understanding that Help-Seeking messages can not include the sponsor, what if a message was broad enough not to allude to a single product? eg. “Ask your doctor about CV medications from Company-X”.
• Jennifer Carroll

747 - Can branded DTC advertising include a claim of 'new' or 'now available'?
• Jennifer Carroll

137 - Would there be an issue with an online banner ad that is exempt from PAAB review linking through to a PDF of the products' Product Monograph?
• Jennifer Carroll

657 - I'm working on building an app for a pharma client. It's a companion for a drug they market. But I'm concerned that the review section in the App Store will put us at risk of being non-compliant. Do you have any suggestions to help?
• Jennifer Carroll

656 - In a DTC Consumer Brochure discussing treatment options for a given disease, can narcotic treatments be included in a balanced list of treatment options? We are assuming a Consumer Brochure is not defined as advertising under the Narcotic Control Regulations s70.
• Jennifer Carroll

645 - Hello PAAB! Can sales representatives distribute a tool that was approved by PAAB as DTC to physicians to provide to potential patients? Would this tool need to be re-submitted through PAAB as unbranded patient material? Thank you!
• Jennifer Carroll

643 - If a DTCI Consumer Brochure closes with a 'help-seeking' message, would it still be considered a Consumer Brochure, or would it be reviewed as a Help-Seeking Announcement (or a combination of the two)?
• Jennifer Carroll

641 - Hi PAAB. Can you advertise a drug to the general public if it is indicated for a condition/disease not listed in schedule A.
• Jennifer Carroll

612 - In the context of a Consumer Brochure, is it permissible to provide DINs for a balanced list of medication options?
• Jennifer Carroll

609 - Hello. Can a pharmaceutical company post a tweet on its Twitter platform about its product winning a research/innovation prize? For example, "Congratulations to Product X for winning the 2017 YZ Prize!"
• Jennifer Carroll

607 - Does a HCP-directed website for a Schedule D vaccine need to be gated?
• Jennifer Carroll