540 - Hello, Suppose a vaccine product launches a branded Facebook page: The rules surrounding promotional posts are relatively clear, but what are the guidelines are on content curation? For example, including a link to an article from a publisher such as the CBC that discusses the condition but with no mention of the brand, or sharing a post from a lifestyle blog that similarly does not reference the brand/vaccine but may be relevant to followers of the page. The Health Canada policy on "The Distinction Between Advertising and Other Activities" does not seem to include this particular type of scenario explicitly. Could you provide some guidance or a link to the relevant guidelines? Thank you.
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For vaccines which are schedule D products only [i.e. do not have a dual drug schedule (schedule D and prescription)], manufacturers may promote the therapeutic use of their vaccines for the prevention of the indicated disease in consumer advertising. When creating a branded Facebook page, it is important to remember that promotional environments that have been created by a Canadian sponsor or for a Canadian audience is subject to Canadian advertising regulations. Any links/posts on this site are inherently linked to the brand, even if the link/post content is strictly related to the disease/condition AND even if the links/posts were independently generated as described in your question. As such, these links/posts should be assessed to ensure that they may be connected to the brand (e.g. no potential off-label implications). The PAAB can provide an advisory review for Rx & Schedule D consumer materials based on interpretation of the Food and Drugs Regulations and the Health Canada policy document “The distinction between advertising and other activities”, the interim guidance on fair balance in DTC advertising of vaccines, the Food and Drugs Act and the Food and Drug Regulations. See the fee schedule on our website for details.
