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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298 - We have a DTC/I campaign moving forward (disease awareness, unbranded). In the treatment section, there will be an outline the different medication options indicated for treatment of this disease. A listing of the benefits and risks associated with medication will also be listed. Because this is a DTC/I content and it contains a listing of ALL indicated products with no links to branded sites, we believe this to be PAAB exempt. What is your recommendation?
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296 - We understand how gating works for things like banner ads on sites where medical registration is required to log in. On sites where any user can purchase access (medical journals, for instance), or where large institutions like universities often have blanket access, is a post-login screen still considered "post-gate" for advertising purposes?
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295 - Hi there, I was wondering if your review procedure for DTCA and DTCI advisory opinions occurs in accordance with chapter 8 and s 9.8 of the PAAB Code. More specifically, do you have the same rights to clarification by telephone or correspondence, meeting, escalation to the Chief Review Officer, and appeal? Thanks in advance for your answer.
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291 - My understanding is that advertising of medical devices such as injectors are not governed by PAAB. However, if a auto-injector can only be used with a specific medication, and one advertises the injector to consumers, is there not a direct association of device & drug? In other words, if the device is so closely connected to the drug, should it not also be subject to PAAB advertising rules, despite the fact that technically, it is a device, not a drug?
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283 - We are considering a partnership that will allow us to place unbranded, disease awareness information into a variety of large public health portals. The portals contain disease awareness information but also have separate areas that disseminate drug specific information. (We are not providing any drug specific information.) As part of this partnership, we are being offered the ability to have banner ads run throughout the site. The ads are not just for our unbranded content. There is the potential for us to have branded ads that point to our gated product-specific website. The banner ads are "run of site" and there is no influence on where they appear within the portal. There are two possible situations that we are concerned about. Our branded ad appears on a page where our unbranded disease information resides through random placement. Our unbranded disease awareness ad lands on a page which contains related drug information through random placement...
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240 - Hi, I was told that an unbranded piece that would be in a waiting room would be direct to consumer, and those which would be in the doctors office are direct to patient. Is this correct?? IF SO, then what are the differences in terms of regulations? For example, what can be said in an unbranded piece in a waiting room that cannot be said in a piece designed for the doctor's office?
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217 - We are holding a patient conference where there will be sponsoring companies exhibiting. Some are companies that have Rx products and some are companies with OTC products. What are the guidelines for the exhibitors in both cases? What are the limitations, in particular, for the Rx product companies with respect to promoting their therapeutic products? The audience is a mix of patients who have several different diseases, as well as the general public.
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196 - I understand a branded paid search ad cannot use keywords that go beyond name-price-quantity. However, if a person searches for the brand name keyword in conjunction with the disease-state keyword, does this not identify them as a patient or someone who is already knowledgeable about the product? Could a branded ad be presented if the searcher has already made the brand-disease connection themselves?
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151 - If a pharma company sponsors a direct to consumer information (DTCI) site for Disease Awareness, can it talk about therapies (if they are all discussed equally, both drug and non-drug therapies)? I believe this to be "Yes". Assuming that, can the site also link from the therapy descriptions to branded drug websites as long as it handles all treatments equally?
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127 - On the website: http://fightosteoporosis.ca/ the copyright notice says: "Copyright C 2010 A research based pharmaceutical company" This doesn't seem right to me, I would expect a copyright notice to clearly state the site's owners. Investigation shows that the site is operated by Warner Chilcott (who market Actonel) but a lot of digging is necessary to get that information.Is this on-side with PAAB regulations?
