277 - Assuming you can ensure that your web platform is only being accessed by Canadian physicians, what are the rules about the content that is on the website? Does the fact that the physician agrees to be "subscribe" open a channel to the information being PAAB exempt on the premise that the physician "Requested" this information? We are thinking of CME materials, disease-relation information (with and without drug mentions), videos of speaker conferences, etc.) We are also thinking of information about the sponsor's ongoing clinical trials.
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I am not sure I fully understand the question. Please call me if I am off topic. Information provided to an individual in response to a request for information that has not been solicited in any way is not considered to be advertising for the sale of a drug and is therefore exempt from PAAB review. This specific exemption applies only when the information provided is limited specifically to that content which was requested by the HCP. Note that the mechanism for requesting this content and the mechanism for receiving it must be kept completely separate from drug advertising. For any information other than that which was explicitly requested, one must assess whether the drug advertising regulations apply by using the Health Canada policy document "The Distinction Between Advertising and Other Activities". If the advertising regulations apply, the content should be submitted for PAAB review. Also see PAAB code section 1.5.
