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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In cases where the website doesn't have a rigorous mechanism preventing members of the general public from consuming advertising content which the regulations only permit for HCPs, then the manufacturer must take steps to ensure that the general public won't arrive onto the site in the first place. Pages on a website are de-indexed so as not to appear as an organic search result. In the absence of a password gating mechanism, to the extent which is within the manufacturer's control, you need to ensure that the only way for someone to arrive to this site is by:
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entering the URL which was obtained through a means only accessible to HCPs
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clicking a link from an HCP gated environment
This can be done quite effectively by using a "No Index" command meta tag on EVERY page of the website. The general principle is always that the general public should not have access to a site when its content exceed the consumer regulations.
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