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    • L

      Unbranded ad link to guidelines
      • llmktg

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      Jennifer Carroll

      Hello @llmktg

      Acceptability would be assessed during the review process. Linking to the homepage/cover page of the complete guidelines, is likely permissible with the understanding that they are recognized Canadian consensus guidelines. For unbranded ads, the linkage should not contravene the principles outlined in Code section 7.5. There are some scenarios where it could be challenged. As an example, if the unbranded piece speaks to a drug class for which the use is off-label in the guidelines.

    • A

      PAAB-exempt name-only communications
      • ALee

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      Jennifer Carroll

      Hello @andrewleeson

      The added clarification copy “however, linking a name-only banner ad to the TMA renders it non-exempt from preclearance as this constitutes a link to therapeutic messages” was added so as to help avoid the misinterpretation that just because there “should not be an issue linking such banner” meant that the banner remained exempt. The activity of linking the banner to a therapeutic message renders it no longer exempt. We did not believe that was clear with the initial response.

      We will remove 517 to help reduce confusion. Please consider the response in 330 to be accurate: “A piece containing only the message "Drug X is coming soon" with absolutely no other message (implied or stated) within the piece AND absolutely no link to therapeutic or promotional messages is exempt. Note that the manufacturer is responsible for ensuring that this message is employed only AFTER the product has been approved by Health Canada. It is prohibited to advertise a drug product prior to Health Canada approval.”

    • G

      Linking from a branded HCP site to a non-promotional website with HCP resources.
      • gbrl88

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      Jennifer Carroll

      Great question @gbrl88

      Question 654 is a great primer for this question.

      The same response applies to a HCP audience. All links must be assessed for acceptability within the context of the brand. Note that a key point for considering the link, is that the site is an authoritative independent third party site. A direct link to off-label content would not be acceptable even in the presence of a second gating mechanism.

    • Jennifer Carroll

      764 - Dear PAAB, Can we have an e mail (APS sent to HCPs) linking to a patient support program provider's (3rd party) website or patient association website? Thank you.
      • Jennifer Carroll

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    • Jennifer Carroll

      759 - We want to develop an unbranded, ungated website that we plan to send to ASC. The content is about adherence and as such is appropriate for all audiences. Can we develop unbranded promotional tools, like banner ads on NEJM, that direct HCPs to this site?
      • Jennifer Carroll

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    • Jennifer Carroll

      754: We want to develop an unbranded, ungated website that we plan to send to ASC. The content is about adherence and as such is appropriate for all audiences. Can we develop unbranded promotional tools, like banner ads on NEJM, that direct HCPs to this site?
      • Jennifer Carroll

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    • Jennifer Carroll

      720 - What are the rules regarding using similar graphic symbols for branded PAAB approved promotional pieces addressed to HCPs and branded DTC materials for the same OTC product. Is it acceptable that they have the same graphic elements such as icons to illustrate the approved claims/indications?
      • Jennifer Carroll

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    • Jennifer Carroll

      716 - Hello, I'm looking for where to find guidance regarding regulations for executing a 'help seeking' DTC campaign for vaccines at the same time as a branded DTC vaccine campaign. Given the DTC nature, pre-clearance would likely be through ASC. I've reviewed the guidance from Health Canada at length and am well aware of the criteria for help seeking. My understanding is that the help seeking and branded campaigns must be different (ie: in colour, tag lines etc) and not linked in any way, but I'm unable to find specific direction. I'd like to be more clear on how the campaigns must be different, assuming they are not linked in anyway (visually or otherwise), and if/how they may be executed concurrently. ie: can a vaccine help seeking TV ad be on during the same time a vaccines DTC branded banner ad or social media campaign is running (again, assuming not linked in any way). Thank you in advance for your assistance.
      • Jennifer Carroll

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    • Jennifer Carroll

      705 - Can a non promotional website that is not subject to review and is only available to verified Canadian HCPs link to a post-gate landing page for a PAAB approved branded website?
      • Jennifer Carroll

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    • Jennifer Carroll

      691 - With regards to the PAAB-exempt regulations, and the requirement to not link to product information - can you confirm if the definition of linkage is in the language used in the piece? For example, if you had a webinar invitation that had only the product name (no indication, disease information, etc) however that invitation was inviting someone (via website link) to a webinar/registration page etc that was all PAAB reviewed/approved, is the invitation still PAAB exempt or by virtue of having a weblink (or intention to direct to PAAB-approved material if it were paper copies etc), is the invitation now in scope of PAAB review?
      • Jennifer Carroll

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    • Jennifer Carroll

      675 - We run a website that contain unbranded disease awareness information as well as unbranded drug information. Are we permitted to leverage our website to run targeted ads that link to sponsored DIN-gated sites?
      • Jennifer Carroll

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    • Jennifer Carroll

      654 - Dear PAAB, Our Pharmaceutical Company is planning to do a Patient Support Program gated website; we will send this website to PAAB for review. We would like to add links to an independent patient association website that has different resources for patients. If we link to the home page of the patient association, will PAAB need to review the entire website even if we with a disclaimer that they are leaving the company website? Can we link to separate documents (e.g. disease state , treatment options)? In this case does PAAB need to review each document ? Since our website is branded are these going to be reviewed as branded pieces? Thank you.
      • Jennifer Carroll

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    • Jennifer Carroll

      577 - Hi - I understand that as per Section 6.6iv, an email informing HCPs about 'updated provincial formulary criteria for Drug X' would be considered PAAB exempt (if there were no linkage to therapeutic or promotional claims). Could you provide clarification on whether including a website link to the full formulary list of a province would still be considered exempt? Note that this formulary list contains criteria specific to Drug X.
      • Jennifer Carroll

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    • Jennifer Carroll

      574 - I intend to submit a non-branded APS into PAAB shortly. One call to action we are considering is a link to a URL that has been ASC approved (but not PAAB approved). We intend to link to not the whole site, but rather a particular section of the site. Would this subject the entire website to PAAB review?
      • Jennifer Carroll

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    • Jennifer Carroll

      558 - If we are developing a postcard with a link to a patient education website on it (website will go through ASC approval) that is designed for the sales rep to give to an HCP to give to their patients, will PAAB have to review the entire website who's link is on the card? The website will have nothing brand specific, it will display all treatment options for patients, however it will have the company logo on it. Thanks!
      • Jennifer Carroll

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    • Jennifer Carroll

      481 - Is it possible to refer to CME content on a web site in an unbranded email to HCPs?
      • Jennifer Carroll

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    • Jennifer Carroll

      480 - Is it possible to link a site with CME content from a gated, branded website? If so, is it possible to identify the tab as leading to CME content? Would it be possible to link to a CME-containing site using an interstitial page/disclaimer between this site and a branded website?
      • Jennifer Carroll

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    • Jennifer Carroll

      426 - Can I post a branded online banner on a website such as Canoe santé that already provides information on a prescription drug (i.e. there is information on the drug and the disease it treats).
      • Jennifer Carroll

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    • Jennifer Carroll

      402 - Hi, I am looking for a ruling on the following scenario. If a sales rep is using a PAAB approved, Un-branded, Disease state promotional piece to engage an HCP in a non-product related discussion. If, during that discussion, the physician asks that representative a product specific question, i.e. "What is the clinical data for Product "X" in the disease state we are discussing?”. Is the rep allowed to answer the question and switch to a product based discussion that incorporates PAAB approved promotional pieces? What specifically can the rep do in a situation like this where the use of PAAB approved messaging and promotional pieces are strictly reactive?
      • Jennifer Carroll

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    • Jennifer Carroll

      372 - When advertising to the HCP target via appropriately gated sites, what are the restrictions around static content? Can a drug ad be placed within relevant content? or target the content on the site specifically?
      • Jennifer Carroll

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