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  4. Bypassing gating
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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.

Bypassing gating

Scheduled Pinned Locked Moved Electronic Media
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  • S Offline
    S Offline
    s_mo
    wrote on last edited by
    #1

    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?

    Jennifer CarrollJ 1 Reply Last reply
    0
    • S s_mo

      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?

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

      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).

      S 1 Reply Last reply
      1
      • Jennifer CarrollJ Jennifer Carroll

        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).

        S Offline
        S Offline
        s_mo
        wrote on last edited by
        #3

        @jennifer-carroll Thank you!

        D 1 Reply Last reply
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        • S s_mo

          @jennifer-carroll Thank you!

          D Offline
          D Offline
          dmauri
          wrote on last edited by
          #4

          @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?

          Jennifer CarrollJ 1 Reply Last reply
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          • D dmauri

            @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?

            Jennifer CarrollJ Offline
            Jennifer CarrollJ Offline
            Jennifer Carroll
            wrote on last edited by
            #5

            Hi @dmauri

            Yes, controlled distribution of QR codes or extended URLs to validated patients, would be acceptable to bypass the DIN gate.

            D 1 Reply Last reply
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            • Jennifer CarrollJ Jennifer Carroll

              Hi @dmauri

              Yes, controlled distribution of QR codes or extended URLs to validated patients, would be acceptable to bypass the DIN gate.

              D Offline
              D Offline
              dmauri
              wrote on last edited by
              #6

              @jennifer-carroll Thank you for the quick response!

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