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456 - We have several questions regarding risk of linkage between disease/indication and another company's product (brand name or non-proprietary name) when purchasing keywords for Search Engine Marketing for a disease-support website and App (both are unbranded) for patients: a) Can we use a competitor's prescription product brand name as the keyword, when the brand name is not marketed in Canada? i. Same question - this time the non-proprietary name is the keyword? This question is to address situations in which the same medicinal ingredient is marketed in Canada but under a different brand name. b) Can we use a competitor's non-prescription product brand name as the keyword, when the brand name is not marketed in Canada? We understand linkage between product and indication in not an issue in this situation; we would like to know if it is still acceptable (morally/ethically). i. Same question - this time the non-proprietary name of the non-prescription ...
• Jennifer Carroll -
455 - What is the recommended mechanism to validate Healthcare Professional status (i.e. gating mechanism) for a website with potentially some consumer advertising content? Some websites ask for Canadian professional license number, but is it a requirement to verify this information (e.g. license number, name, etc.) once it's obtained? If so, with what database/organization?
• Jennifer Carroll -
418 - Explanatory note 4.4.3 states the following: "Where mandated by the consumer advertising regulations [s6.5.6], the web link destination must either be gated or de-indexed from search engines. If the site is gated, the URL or electronic link promoted in the APS must bypass the gate such that password entry is not required to access these disclosure documents. The URL and electronic link must therefore be promoted only to HCPs." Could you please explain the criteria a website must meet to be considered "de-indexed"?
• Jennifer Carroll -
416 - We are creating a website for HCPs using Responsive Web Design, in which one set of content (text, images etc.) will automatically be populated into different layout placements based on the size and configuration of the screen on an HCPs device (table, smartphone, laptop etc.). We would like to submit only 2 breakpoints for review (desktop & smartphone), because the tablet version will either follow the desktop size/dimensions - or the mobile, depending on the orientation of the screen (vertical or landscape). Would providing layouts, copy and wireframes for the 2 breakpoints satisfy PAAB submission requirements? Will you also require screenshots of the tablet version? Will the different breakpoints require separate submissions? Or will they be reviewed separately but as a series fee?
• Jennifer Carroll -
412 - We have a slide deck that is being presented to HCPs by members of our medical team. This deck is PAAB approved. We have a few questions. Can we record the session and place it on our HCP gated portal for other HCP's to benefit from? Does the recording require PAAB approval? In the post-production of the video, can we add chapters to the video so if physicians wanted to watch the video in segments, they can? Thank you.
• Jennifer Carroll -
378 - Creating a website which makes reference on use of botox and latisse. Both are prescribed drugs. Does this create an issue with Health Canada guidelines? We are not advertising the products but reference them as to what they can do for patients as well as the possible side effects.
• Jennifer Carroll -
305 - For search engine marketing, our researcher has indicated the French speaking and English speaking Canada use different vocabulary when searching for our therapeutic disease sites or product web sites. We have traditionally had our PAAB approved Search Ads and keywords directly translated from English into French and then submitted the French for Approval.
• Jennifer Carroll -
290 - We are placing promotional branded banner ads (no claims) in third party HCP gated websites that will drive traffic to our own gated HCP specific website. The third party site is intended for HCP's only. a) As the third party site audience is validated to be HCPs only, is this sufficient to enable bypassing our gating mechanism and bringing the HCP directly into our site? b) We are intending to bring the HCP to our top level product overview page. For future use, are there any issues with deep linking the physician into other areas of the website? (ex: Dosing, patient support, safety)
• Jennifer Carroll -
268 - Dear PAAB, We are developing a gated HCP website that requires the HCP to enter his/her license number to gain access to the site. Who provides the database of physician license numbers which our site will "ping" (cross-check against)? If it is an outside source/organization, is there any fee for this?
• Jennifer Carroll -
230 - Hello, I am developing a free iPad application that provides healthcare education presentations for HCPs only. This app will be available for download from Apple's app store. What kind of user gating am I required to have for this app? Is a disclaimer + check box certification of the HCP status enough? Furthermore, I have heard about new sections being implemented in the PAAB code that are related to this - possibly referred to as "access control". Do you have any information concerning these guidelines? Thank you!
• Jennifer Carroll -
199 - How do you review electronic detail aids created for tablets/iPads? Which technical features can be included in electronic details that would allow for easier detailing over a tablet/iPad? - Search keywords - highlighting sections - animations - organizing content into tabs (dosing, safety etc)
• Jennifer Carroll -
168 - For our Vaccines web sites which are branded, we would like to include a link to our unbranded Digital Video News Release (DVNR) which will be housed on YouTube. We are also considering storing a PDF version of our unbranded matte stories on the website. Is there any concern with placing unbranded materials on a branded web site? Does it matter if it is a Vaccine or Rx product?
• Jennifer Carroll -
140 - If we place an ad in an HCP-focused journal, and provide a link to an HCP-focused website (either typed in or scanned using a 2-D scan code), can we assume that the audience has been sufficiently vetted as HCPs and provide branded drug information to them? This would be in lieu of asking for licence numbers or other means of identification.
• Jennifer Carroll -
128 - We are considering creating a web site that is for healthcare professionals (HCP)only. What are the minimum requirements for 'gating' the site? As this may span multiple products, DIN is not appropriate. We will be looking to use a UserID/Password combo. What is our responsibility as a pharmaceutical company to ensure that the person signing up for an account is indeed a HCP? Can it be as simple as getting the HCP to agree to the 'Terms of Use'?
• Jennifer Carroll -
125 - Most brands have quite lengthy balance and we are looking on how to incorporate this into banner ads that include product claims. If the banners are animated and they rotate/transition automatically from claims to balance, is that okay. This would be the same as turning pages in a detail aid....correct?
• Jennifer Carroll