Guidance on Gating Mechanisms for HCP Digital Asset
Jennifer Carroll last edited by
We are pleased to announce that guidance on gating mechanisms for HCP digital assets has now been posted.
In the recent years, it has come to the attention of PAAB and Health Canada, that there has been variance in the application of "sufficient barrier" when it comes to limiting healthcare professional advertising from being accessible by consumers. Considering this, PAAB has worked with Health Canada to generate guidance on the creation and implementation of gating mechanisms which would qualify as presenting a sufficient barrier between the general public and healthcare professional advertising.
The gating requirements have not changed. This guidance clarifies the existing Health Canada requirements and provides insight into how those requirements can be met. In fact, a new option is outlined to further assist advertisers in meeting gating requirements. The new option is modeled after the gating methodology that is currently predominantly used across this industry. However, as the option addresses areas in which current gates fail to meet requirements, some gates will need to be fortified. It is understood that this will take time. Until January 2024, insufficiently robust gating mechanism noted through our monitoring activities will simply trigger a courtesy email informing the manufacturer of the gating deficiencies and providing potential solutions where applicable.
Where relevant during preclearance reviews, the PAAB will continue to remind advertisers that an effective gating mechanism will be required.
PAAB will not provide "approvals" for gates, however we can assess if the approach and guardrails proposed by the company would appear to be sufficient in the context of a formal opinion submission.
We hope that you find this guidance helpful. If you have any questions, please post them below or in this category: HCP Gating.