Bypassing gating
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Would a unique link sent to HCPs which allows them to bypass the gating on a PAAB-approved gated promotional website on a product be acceptable? If the website includes information on other products, should the access be restricted to certain pages only or could they navigate throughout the whole site?
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Hello @s_mo
A bypass link through the gate is acceptable when provided through controlled distribution to validated HCPs (e.g., rep distributed or through a pre-validated HCP mailing list). Please see PAAB Supplementary Guidelines: Online Activities, section 2.The Target Audience. As they have already been vetted as an HCP, they can have access to multiple brands. How they are driven to this space and how the brands are presented may influence acceptability. By this, we mean that the linkages will need to be assessed to ensure that all criteria of the code are maintained. For example, if the link is from a branded space that leads the user to a list of brands, it must be clear what these brands are used for and there should be no implications for product use which are unclear, unsubstantiated or unacceptable. Another point of consideration will be presentation of balancing information. Consider Guidance on Base Fair Balance Level Selection and Placement, specifically section Detailed non-linear tools (e.g. Websites and Apps).
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@jennifer-carroll Thank you!
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@Jennifer-Carroll I imagine that we can also provide QR codes or extended URLs on branded patient-directed APS (brochures, wallet cards, etc.) that bypass the DIN gate for branded patient websites?
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Hi @dmauri
Yes, controlled distribution of QR codes or extended URLs to validated patients, would be acceptable to bypass the DIN gate.
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@jennifer-carroll Thank you for the quick response!
