760 - What type of gating is required for a HCP website for a schedule 1 product (narcotic)? is de-indexing considered a form of gating? What type of information can be available pre-gate? can information around a patient support program be made available pre-gate for a schedule 1 (narcotic) product?
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Yes, de-indexing is considered a form of gating. Note that the de-indexed URL should also be something that is not easily guessable (controlled distribution). For example, “BrandX.ca” would not be acceptable. Neither would “BrandXHCP.ca” or “BrandXresources.ca”. There should be some aspect of the URL which is not easily guessed. We suggest a set of random characters/numbers.
Note that advertising of narcotics falls under the Narcotic Control Regulations and the Controlled Drugs and Substances Act. Advertising of narcotics is prohibited to the general public (this includes reminder ads that would be limited to only the product name, price and/or quantity). As such, it would not be acceptable to have a landing page which makes mention of the narcotic. In addition, the inclusion of promotions for a patient support program in a public space, would not be acceptable.
Please also be advised that Health Canada has provided additional guidance on the promotions of opioids. Please see: https://www.canada.ca/en/health-canada/services/drugs-health-products/reports-publications/medeffect-canada/submission-targeted-rm-plans-commitments-prescription-opioid-containing-products-guidance-industry/document.html#a3.2.3.3 and https://www.canada.ca/en/health-canada/services/drugs-health-products/drug-products/announcements/additional-restrictions-advertising-opioids.html
