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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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587 - Can you please tell us more regarding gated medical information websites. What would be considered an effective and PAAB compliant gate? Verify each HCP by License #? HCP number pattern (do we need to use specific pattern depending on the type of HCP eg: Nurses, Pharmacists, Physicians. and the province)? Thanks
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555 - Can we provide a link from our disease state page on our local website to our global disease state page containing information about the same topic? If a disclaimer pops up prior to the user leaving the Canadian website and viewing content on that disease state global page, are we able to do this?
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554 - On an HCP gated website that provides branded drug information, is it mandatory that the very first page after the gate is cleared be the "safety information" for that drug? Assuming the "safety information" link is accessible from the main navigation menu, can the landing page after the gate be some other content? Thanks.
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479 - According to section 7.4, it sounds like Canadian corporate websites need to be reviewed by PAAB. However, I have not come across any that have the PAAB logo. Can you please clarify? From a previous Q&A it sounds like corporate websites have to be written with consumer regulations in mind too since they are publicly accessible. I guess that means we cannot have a write up on the therapeutic areas on the corporate website because that would be linking the therapeutic area to the product, because the product info would be found in the Product Monographs that are linked to the site. Can you please clarify this for me? Thank you!
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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 ...
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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?
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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"?
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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?
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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.
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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.
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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)
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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?
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