Consumer-facing Institutional Messages
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Hello! We are working on developing a consumer-facing institutional message campaign with our clients. The objective of this campaign is to reiterate the aspiration of our client—Company X—in being committed to curing/ending suffering from Condition Y. Our client’s portfolio includes multiple treatments for Condition Y as well as other diseases. Messaging on these APS might include statements like "We all play a role in ending the suffering caused by Condition Y. Forever." or "Company X, together with the healthcare community, is committed to putting an end to Condition Y." The banners and/or posters associated with this message would directly link to videos which highlight Company X’s commitment in supporting healthcare institutions that treat Condition Y. Given that this campaign would not explicitly highlight one treatment in particular and does not include a help-seeking message, we are hoping to gather the PAAB’s opinion on the degree of pre-clearance that would be needed for this type of communication.
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Hello @matt-s17
The Distinction Between Advertising and Other Activities states:
An institutional message is defined as a communication (e.g., brochure, published article, prospectus, annual report, etc.), which provides information about a pharmaceutical manufacturer, or other institution, concerning its philosophy, activities, product range (by name), financial details, area of future development or research, etc. Such a message may be a nonpromotional activity in the following circumstances:
- the purpose of the communication is clearly to provide information about the institution rather than about the drugs being marketed, developed or researched,
- information about the drugs being marketed, developed or researched is limited to the name and therapeutic use of the drug, and
- no emphasis is given to any one or more products, or their benefits
The activity described above seems to place emphasis on a particular therapeutic area and class of products which the sponsor has a vested interest and therefore would fall in the scope of advertising. If the intent is for the messages mentioned above to exist in the consumer space and be targeted at consumers only, it would be subject to consumer advertising regulations and an advisory opinion may be provided by PAAB, AdStandards or sent directly to Health Canada. If there is a possibility that the message/campaign will be targeted at HCPs in any way, it would be subject to the PAAB Code and should be reviewed by PAAB.
