Unauthorized Use of Content on this Site: The responses, guidance, and advisories provided by the Pharmaceutical Advertising Advisory Board (PAAB)—including, but not limited to, those available through the PAAB Forum, the PAAB website, and any PAAB correspondence—are specifically intended to assist individuals navigating the PAAB preclearance system. Repurposing or reproducing this content, or using it for model training or any related purposes, is strictly prohibited without the express prior written consent of PAAB. This includes, but is not limited to, the use of such materials in automated systems, machine learning models, or artificial intelligence applications.
502 - Is Pharma allowed to sponsor an independently-developed, physician-managed, online discussion forum? Pharma would have no involvement other than to provide funding for its development. What if the discussion forum is managed by Pharma's communication agency?
-
It’s not a matter of “can you?” It’s a matter of whether it is advertising? This assessment requires consideration of all 7 factors outlined in the Health Canada document “The Distinction Between Advertising and Other Activities”. PAAB can provide an opinion in consideration of all factors that are applicable in your particular case (see the fee schedule on our website).
If it is not advertising, it is not subject to the advertising provisions. If it is advertising, the answer is still “yes” but the pharma sponsor is responsible to ensure that the content falls within the federal advertising regulations.