DTCA/I, consumer secondary audience
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The responses, guidance, and advisories provided by the Pharmaceutical Advertising Advisory Board (PAAB),
including but not limited to those available through the PAAB Forum, the PAAB website, and any PAAB
correspondences, are specifically intended to assist individuals navigating the PAAB preclearance system.
Repurposing or reproducing this content without written consent from the PAAB Commissioner is strictly
prohibited. This prohibition includes, but is not limited to, use in machine learning or AI models.
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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.
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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?
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540 - Hello, Suppose a vaccine product launches a branded Facebook page: The rules surrounding promotional posts are relatively clear, but what are the guidelines are on content curation? For example, including a link to an article from a publisher such as the CBC that discusses the condition but with no mention of the brand, or sharing a post from a lifestyle blog that similarly does not reference the brand/vaccine but may be relevant to followers of the page. The Health Canada policy on "The Distinction Between Advertising and Other Activities" does not seem to include this particular type of scenario explicitly. Could you provide some guidance or a link to the relevant guidelines? Thank you.
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536 - Hello. I work in the advertising industry, and have been discussing with a prospective client a direct mail piece in support of a prescription product. I understand that you cannot communicate the product name and specify what what malady it treats, but it must be a generic message advising to speak to their healthcare practitioner. My question is that if I were able to source a list of individuals who have reported having this condition, could I send this generic unbranded awareness piece to that identified person?
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499 - We are experienced in submitting DTCI campaigns through regulatory. In these cases, the focus is on the disease and when mentioning drugs, we discuss all treatments indicated for that disease (because there cannot be undue emphasis on any one drug). However, we wish to know about the DTCA of vaccines. For example, are we allowed to talk about the indication/side effects/dosing, etc for one vaccine specifically without mentioning the other vaccines indicated for the prevention of the same disease? In this case, it'll have the "undue emphasis" which is not permissible for schedule F drugs.
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447 - For consumer surveys which are meant to gather information about current knowledge/attitudes on a certain medical condition and contains no medical information, does it need to be submitted to PAAB along with the rest of the DTCI campaign? We plan to use the survey results as a means to tailor content that addresses some of the knowledge gaps/attitude of consumers. Thank you kindly.
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