Navigation

    Forum

    • Register
    • Login
    • Search
    • Categories
    • Recent
    • Popular
    • Users
    • Groups
    1. Home
    2. PAAB Q&A
    3. Electronic Media
    Log in to post
    • Newest to Oldest
    • Oldest to Newest
    • Most Posts
    • Most Votes
    • N

      SEM Keywords
      • NKH

      2
      0
      Votes
      2
      Posts
      47
      Views

      Jennifer Carroll

      Hello @nkh
      It would not be acceptable to purchase other sponsors brand/generic name even if it was a product for use before or along with the sponsors product as this would create a link to the therapeutic use of the sponsors product for patients who are on the other brand but not the sponsors. This would be considered direct to consumer advertising which goes beyond name, price and quantity and which advertises the therapeutic use of the product.

    • J

      Google Ads
      • jriordan

      2
      0
      Votes
      2
      Posts
      68
      Views

      Jennifer Carroll

      Hello @jriordan

      Yes, pharmaceutical product can have a webpage. Section C.01.44 of the Food and Drugs Act Regulations restricts the advertisement of a Schedule F drug (prescription drugs), to the general public to name, price, and quantity. If they are prescription and go beyond the limitations of the consumer regulations (name, price, quantity), the content should appear behind a gate to limit to the acceptable audiences (patient information or HCP advertising).

      Google Ads or search engine optimization (SEO) generally occurs in the ungated public space and means that the totality of the content (search terms, descriptor, gate landing page and URL) cannot exceed the consumer regulations.

    • C

      Brand name only
      • charlton

      2
      0
      Votes
      2
      Posts
      56
      Views

      Jennifer Carroll

      Good Morning @charlton

      If the surface of the ad does not prompt the inclusion of indication and fair balance, then yes, it would be acceptable to not include the indication and fair balance on the static ad. If there are claims/therapeutic mention on the static ad or the combination of the static ad and the landing page, this would prompt the inclusion of the indication and fair balance on the first surface with a marketing benefit claim. As a reminder, a marketing benefit claim can be explicit (e.g. text) or implicit (e.g. images).

    • K

      Linking mid-level to high-level for narcotics
      • kshulist

      3
      0
      Votes
      3
      Posts
      57
      Views

      K

      @jennifer-carroll Thank you!

    • G

      Facebook personal message
      • gnadeau

      2
      0
      Votes
      2
      Posts
      111
      Views

      Jennifer Carroll

      Hey @gnadeau

      Private messages through services/platforms like LinkedIn, Facebook or other social platforms are viewed the same as an email. These are simply different platforms to perform the same action. Per PAAB Q&A 750 if the communication was unsolicited, it should be submitted for review.

    • L

      Attachment of clinical reprints in an RTE
      • Laurelea

      2
      0
      Votes
      2
      Posts
      180
      Views

      Yin Man

      @laurelea

      Good question. In the same context as described in your previous question Rep triggered e-mails | Forum, a similar principle would apply to the naming conventions for clinical reprints attached to an RTE. Assuming the naming convention is claim-neutral (e.g. Smith, NEJM 2015) as per your example, fair balance would not be required. However, study acronyms are considered different. We review naming conventions in a similar way to subject lines or small space ads, so the RTE would require the appropriate fair balance (level of balance TBD depending on the specific language used in the naming convention) if they contain more than one of the following elements: product name, study endpoint or study name (i.e. study acronym). A combination of more than one of these elements has the potential to allude to a message/claim that requires fair balance.

    • L

      Rep triggered e-mails
      • Laurelea

      2
      0
      Votes
      2
      Posts
      233
      Views

      D

      Hello @Laurelea,

      You are correct. If there are no brand-related claims and no reference to therapeutic use, it would be acceptable to not include fair balance within the piece if the document titles are neutral and claim-free, as per your example. For further information on naming conventions for email attachments, please see PAAB : Resources : Document names and descriptions for external use. Please note that the emails would still be subject to PAAB review as they link to advertising. For more information on the submission of email templates, please refer to Clarification regarding digitization of APS: Helping healthcare product manufacturers plan for the evolving COVID-19 operational context (in particular, the Dissemination section).

      Thanks!
      Danielle

    • C

      Banner Ads
      • cchong

      2
      0
      Votes
      2
      Posts
      712
      Views

      Jennifer Carroll

      Hey @cchong

      Web banners have a small viewing area which amplifies the negative impact that scrolling has on the reading experience. Their geometry combined with the incidental/secondary nature of the attention they are afforded, makes web banner ads particularly sensitive to features that increase the barriers to consumption. The principle that claims and balancing text must be treated equally is always important, but even more so for web banner ads.

      Either of the following are appropriate web banner ad approaches*:

      The product claims and balancing copy are presented complete and whole within one fixed section. The product claims and balancing copy are presented as one entity and the whole entity scrolls automatically (such that claims and balancing copy are treated equally). A multi-frame APS that flips from frame to frame automatically (such that no action is required for consumption of the entire APS).

      *Approaches cannot be combined

    • V

      Podcasts
      • ValerieS

      2
      0
      Votes
      2
      Posts
      670
      Views

      Jennifer Carroll

      Hey @valeries

      As there seem to be a lot of moving parts to this question, we will attempt to provide some broad guiding principles.

      See PAAB Q&A 169 for key suggestions. While it speaks to HCP quotes, it can be extrapolated to experts in their respective fields (yoga, stress management and goal setting).

      If the patient-focused app community is branded, all content accessed through it (including podcasts) would be subject to advertising regulations.
      To help reduce the number of post recording changes, we generally suggest having a pre-reviewed script. When this is not possible, we suggest review of talking points so that the speaker is generally guided in the right direction. Post recording, a full script should be submitted to PAAB. Any copy which does not meet the regulations, will be requested to be removed.

      A similar thought process can be applied to patient interviews. While it is acceptable to have them, they must meet the limitations of patient information. For example, they should not be promotional. Like in PAAB Q&A 169, we suggest having a pre-approved script, or if this is not possible, a list of reviewed questions. The final script will be required for review and approval.

    • N

      Guidelines for Online Activities
      • NIvanov

      2
      0
      Votes
      2
      Posts
      256
      Views

      Jennifer Carroll

      Hello @nivanov
      The section in question (6.6) has been revised and rolled into section 1.5 Materials not Subject to Preclearance of the PAAB Code

      Thank you for identifying the old number. We will update the document accordingly.

    • K

      edirect campaign to HCP
      • Kalli

      2
      0
      Votes
      2
      Posts
      388
      Views

      Jennifer Carroll

      Hello @kalli,

      If the intent of the message is to promote a company sponsored service/offering linked to a brand, and is created and controlled by the sponsor, it is likely subject to advertising regulations regardless of branding elements within the edirect specifically. Remember that when we link advertising and non-advertising, everything becomes advertising. Similarly, when we link branded and unbranded, everything becomes branded.

    • H

      Meta data for product website for patients
      • HollyMed

      2
      0
      Votes
      2
      Posts
      98
      Views

      Jennifer Carroll

      Hello @hollymed

      The PAAB does not require that meta-descriptors for webpages be used. We merely require to review them when they are used. On a side note, there may be reasons to use them (or some other meta data) post gate. For example, some implementations of intra-site(post-gate) search would employ these. But as you’ve pointed out, you’d need to make sure that no content beyond name/price/qty appears in external (e.g. Google) search results. That would be a matter of setting the appropriate robot text. Hope that helps.

    • Jennifer Carroll

      312 - What are the steps to review and approved a website? Does the content of the site may be revised first as independent, indicating the titles subtitles, main menu, submenu, boutons, etc..? And then once approved texts, we submit the entire site with images of each page and approuved content. Or should we submit from the first revision the entire website as one ASP needed to be revised with images of the design which will present content that not approuved?
      • Jennifer Carroll

      3
      0
      Votes
      3
      Posts
      165
      Views

      Jennifer Carroll

      Hey @AnetteCPC

      Multiple factors can potentially come into play. But the most frequent determinant tends to be whether the video is embedded in the website and is ONLY accessible on the submitted website page, then it can be submitted as part of the same review. If the video can be downloaded, shared or in some way consumed where it is not on the reviewed webpage and complete website, it requires a separate submission. Remember that APS are reviewed as a whole as there may be content on the page or website which creates context for the video, which the video alone may not contain.

    • Jennifer Carroll

      760 - What type of gating is required for a HCP website for a schedule 1 product (narcotic)? is de-indexing considered a form of gating? What type of information can be available pre-gate? can information around a patient support program be made available pre-gate for a schedule 1 (narcotic) product?
      • Jennifer Carroll

      1
      0
      Votes
      1
      Posts
      215
      Views

      No one has replied

    • Jennifer Carroll

      755: What type of gating is required for a HCP website for a schedule 1 product (narcotic)? is de-indexing considered a form of gating? What type of information can be available pre-gate? can information around a patient support program be made available pre-gate for a schedule 1 (narcotic) product?
      • Jennifer Carroll

      1
      0
      Votes
      1
      Posts
      53
      Views

      No one has replied

    • Jennifer Carroll

      753: My question is in regards to PIS (Product Information Session) invite templates, Is there any restriction in our reps sending via email an invite to an HCP which has free text specifically to include the date, time, location and speaker. Thanks so much.
      • Jennifer Carroll

      1
      0
      Votes
      1
      Posts
      45
      Views

      No one has replied

    • Jennifer Carroll

      742 - My client is preparing an HCP website that will include brand promotion as well as offer samples. The site will be 'gated' which will involve a landing page that asks the viewer if they are a Canadian physician and require that they input their license number. Does the website require a validation process to ensure that the license numbers and the physician name are accurate? Could the 'validation' be limited to ensuring that the correct number of digits/letters are input (as opposed to confirming that those numbers match to a licensed physician). I look forward to your feedback. Thank you! LC
      • Jennifer Carroll

      1
      0
      Votes
      1
      Posts
      94
      Views

      No one has replied

    • Jennifer Carroll

      50 - To restrict access to patient web site we usually use the DIN as an accepted method of verifying that the visitor is indeed a patient before granting access. But we are currently working on a web site for a drug where the patients never receive the product packaging. Some of them might be able to find the DIN on their drug store receipt but some receipts don't have that information. Are there other accepted methods of restricting access to a patient web site in case the DIN is not available?
      • Jennifer Carroll

      2
      0
      Votes
      2
      Posts
      62
      Views

      NatBourre

      @Jennifer-Carroll Would you agree that this unique URL provided by the physician to the patient should not contain any keywords that could allow patients to find the website while doing a search for the disease state or the product in question?

    • Jennifer Carroll

      712 - We have an online newsletter where we post healthcare-related information, as well as society news pertaining to our association. Our member and supporter base primarily consists of hospital pharmacists as well as a small number of architects, students, and pharmaceutical companies. We can set-up advertising on the site to require a login to limit access by the general public. My concern is with the students who are not yet healthcare professionals, the pharmaceutical organizations, and the small number of architect members. Would their exposure to pharmaceutical advertising go against PAAB standards, even if we include a disclaimer that the advertisements are meant for healthcare professionals only? When we used to have...
      • Jennifer Carroll

      1
      0
      Votes
      1
      Posts
      59
      Views

      No one has replied

    • Jennifer Carroll

      633 - I would like to send an email to verified healthcare professional, that email would not exceed Price, Name, Quantity, would include no claim and have a deep link to access the product monograph of this schedule A product. Do I need to submit such email to PAAB approval if ... 1- the product monograph is only accessible via this email ? 2- the product monograph is hosted on our corporate website (ungated website) ? 3- the product monograph is hosted on a gated hcp website ?
      • Jennifer Carroll

      1
      0
      Votes
      1
      Posts
      156
      Views

      No one has replied