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PAAB Notice
The responses, guidance, and advisories provided by the Pharmaceutical Advertising Advisory Board (PAAB), including but not limited to those available through the PAAB Forum, the PAAB website, and any PAAB correspondences, are specifically intended to assist individuals navigating the PAAB preclearance system. Repurposing or reproducing this content without written consent from the PAAB Commissioner is strictly prohibited. This prohibition includes, but is not limited to, use in machine learning or AI models.

Privacy Policy & Terms of Use

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  • G Offline
    G Offline
    GMC
    wrote on last edited by
    #1

    I understand that the pre-gate for branded patient and HCP websites cannot link to corporate Privacy Policy (PP) and Terms of Use (TOU) due to restrictions set out in Section C.01.044 of the Food and Drug Regulations or Section 3 of the Food and Drugs Act. Can patient and HCP branded websites link to the corporate website PP and TOU pages in the post-gate section of the branded websites?

    Jennifer CarrollJ 1 Reply Last reply
    0
    • G GMC

      I understand that the pre-gate for branded patient and HCP websites cannot link to corporate Privacy Policy (PP) and Terms of Use (TOU) due to restrictions set out in Section C.01.044 of the Food and Drug Regulations or Section 3 of the Food and Drugs Act. Can patient and HCP branded websites link to the corporate website PP and TOU pages in the post-gate section of the branded websites?

      Jennifer CarrollJ Offline
      Jennifer CarrollJ Offline
      Jennifer Carroll
      wrote on last edited by
      #2

      Hi @gmc,

      Yes, the PP and TOU can be linked post gate as the product name and therapeutic use would be restricted to the HCP and patients prescribed the product. In the pre-gate scenario, the appearance of the product name with the links to the therapeutic use are unrestricted and open to the general public. This would be a contravention of the Food and Drugs Regulations.

      G 1 Reply Last reply
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      • Jennifer CarrollJ Jennifer Carroll

        Hi @gmc,

        Yes, the PP and TOU can be linked post gate as the product name and therapeutic use would be restricted to the HCP and patients prescribed the product. In the pre-gate scenario, the appearance of the product name with the links to the therapeutic use are unrestricted and open to the general public. This would be a contravention of the Food and Drugs Regulations.

        G Offline
        G Offline
        GMC
        wrote on last edited by
        #3

        @jennifer-carroll One more question, can unbranded patient and HCP websites (post-gate) link to corporate PP and TOU pages?

        Jennifer CarrollJ 1 Reply Last reply
        0
        • G GMC

          @jennifer-carroll One more question, can unbranded patient and HCP websites (post-gate) link to corporate PP and TOU pages?

          Jennifer CarrollJ Offline
          Jennifer CarrollJ Offline
          Jennifer Carroll
          wrote on last edited by
          #4

          @gmc

          Yes, unbranded patient and HCP websites can link to corporate PP and TOU pages post gate.

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