456 - We have several questions regarding risk of linkage between disease/indication and another company's product (brand name or non-proprietary name) when purchasing keywords for Search Engine Marketing for a disease-support website and App (both are unbranded) for patients: a) Can we use a competitor's prescription product brand name as the keyword, when the brand name is not marketed in Canada? i. Same question - this time the non-proprietary name is the keyword? This question is to address situations in which the same medicinal ingredient is marketed in Canada but under a different brand name. b) Can we use a competitor's non-prescription product brand name as the keyword, when the brand name is not marketed in Canada? We understand linkage between product and indication in not an issue in this situation; we would like to know if it is still acceptable (morally/ethically). i. Same question - this time the non-proprietary name of the non-prescription ...
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continued ... product is the keyword? c) Can we use a competitor's prescription product brand name or non-proprietary name as the keyword, when the product is marketed in Canada? i. Can we use a competitor's non-prescription product brand name or non-proprietary name as the keyword, when the product is marketed in Canada? d) Are we required to submit the SEM campaign (keywords, Ad text, etc) for this disease-support website and App to PAAB or ASC for review? ASC has already reviewed and approved both the website and App.
Response: A-C) Keywords and other Meta data tags that refer to competitor products are prohibited because it is deemed unethical. This applies to products which are approved in Canada and those which are not. This applies regardless of whether the product is Rx or non-Rx. Finally, note that the non-proprietary name is considered a representation for the competitor. D) No you are not required to submit this to PAAB. The PAAB requires review of SEM campaigns tied to online tactics which have been reviewed by PAAB. If these materials have been reviewed by Ad Standards, you may want to inform them of the existence of SEM such they can determine whether they need to review it.
