102 - Can a pharmaceutical company provide ,upon request from a Third party HCP controlled website, a company produced educational slide deck ( disease and treatment) that has not been reviewed and approved by PAAB.The third party website wishes to provide these educational slide kits to their members as self learning resources.
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PAAB code 1.5 lists what is exempt from PAAB review. This slide deck was created by a pharmaceutical company and it contains discussion on drug treatment. As such, it should be submitted for PAAB review if it will be distributed beyond the context of person-to-person correspondences (i.e. beyond responses to an unsolicited request for this specific material). Note that the scenario outlined in your question does not meet the exemption for person-to-person correspondences as such communications should be for the individual's personal use. This is consistent with Health Canada's policy on unsolicited requests for information as per the document "The Distinction Between Advertising and Other Activities". The following is an excerpt from that document: Information provided to an individual about a drug treatment(s) by a pharmaceutical manufacturer in response to a request for information that has not been solicited in any way (by the manufacturer of the drug) is not considered to be advertising for the sale of a drug. Note that the third party site may mention that members can contact a pharmaceutical company's medical information department to make specific requests for information. The availability of this specific slide kit should not be mentioned on the site as the ensuing requests would not be considered "unsolicited". Company-generated editorial material is reviewed under section 7.5 of the PAAB code. Please call the PAAB office if you have further questions about exemptions
