767 - It is not uncommon for employees in a sales or marketing function to have the name of the product they support in their email signatures. If such an employee sends an email to a HCP and attaches materials that are not specific to a product (i.e. unbranded disease related) does that attachment now become an APS and therefore subject to PAAB review due to its association to the product name in the email signature?

  • You are correct in your assumption that this would brand the email and its content. When we link branded and unbranded, everything becomes branded. As the sign-off is content within the entirety of the message, the disease content becomes branded and needs to be reviewed in this context. Note that this would also trigger code section 2.10.1 and 2.4, requiring the inclusion of the indication and fair balance.