DTCA/I, consumer secondary audience
-
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 -
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 -
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 -
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 -
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 -
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 -
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 -
596 - A disease-state piece includes mention of treatments in a balanced manner. It is distributed to consumers as a Consumer Brochure and technically exempt. Can this same piece be distributed to HCPs, or would it have to be revised to meet Editorial APS requirements? Does the content and/or level of detail dictate this?
• Jennifer Carroll -
556 - Hi PAAB, Section 1 of the Code provides that it applies to APS directed to HCPs (as well as patient information distributed via HCPs). Corporate websites target consumers rather than HCPs. However, it seems that PAAB considers corporate websites presenting information on the company's products as corporate APS (s. 7.4 of the Code) that must be submitted to PAAB. Does it mean that the Code also applies to material that does not target HCPs? If the corporate website presents general information on a disease or a class of products, does it need to be submitted to PAAB or would it be considered as DTCI? Thank you.
• Jennifer Carroll -
559 - Exactly when does a 'consumer' become a 'patient' -- is it the point at which they receive a prescription for a specific brand, or when they are dispensed a specific brand? In certain therapeutic categories (eg., epinephrine, insulin), patients receive a prescription for the molecule, which can be associated with multiple brands. At this point before a specific brand is selected, is it permissible for an HCP to expose the 'consumer/patient' to branded material, in order to facilitate brand selection? This scenario assumes that all brand options would contain the identical active molecule.
• Jennifer Carroll -
543 - We are building a website which would contain medical information only. The website will be gated with a registration & log-in process that only allows entry to Canadian HCPs. In an effort to improve the search engine ranking of our website, we would like to optimize our website for organic search (SEO), which would include using a JavaScript log-in page that would allow search engines to crawl the pages beyond the gate. We would not offer the ability to access content on the website without registration and login validation, the purpose of allowing search engines to crawl the pages beyond the gate is simply to allow our website to appear in organic search rankings for specific key word searches. Is this permissible under the Code?
• Jennifer Carroll