276 - If you recorded a speaker event (sponsored dinner conference) and want to post it on a website, can you? What rules is the content subject to and what is acceptable in terms of efforts or means by which you would make HCPs aware of the availability of this recorded presentation?
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If the content is advertising once posted on the website, it requires PAAB review. Please refer to the Health Canada guidance document "The Distinction Between Advertising and Other Activities" to determine whether it is advertising. Note that we'd require a copydeck for a formal review to approval. If you are uncertain whether it falls in the advertising realm, feel free to ask us by using our written opinion service (i.e. provide the content and clarify the context in which it will be posted). Refer to the fee schedule on PAAB website. Here are some examples: If either the website or the recorded event emphasizes or favours the sponsor's product, the recording will be reviewed as a product branded APS (e.g. disease information posted on a product website is reviewed in the context of the brand). If neither the website nor the recorded event emphasize/favour the sponsor's but they discuss issues relating to drug therapy, the recording will be reviewed as an editorial APS. Disease information with no mention of drug therapy or even issues relating to drug therapy placed on a corporate website in a manner which does not link to a product in any way would be exempt from PAAB review.
