Separate submission for 2 sections of the same website
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Hello there,
Would it be possible to make two different submissions for two sections of the same website? The first section is for the corporate part, and the second one is for the branded and gated HCPs portal on which HCPs find information about the only medicine marketed by the pharmaceutical company for now. Both sections are linked to each other through a Call To Action button, and there will be a gated entry to go from the corporate section to the HCPs portal.
The corporate section needs to go online more quickly. The idea would be to have it live before the HCPs portal and use a temporary message to indicate that the HCPs portal will be live soon.
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Hello @mbeauclair
Based on the description, it would likely be required to be two separate submissions. Note that when you submit the initial corporate part, you’ll want to be clear about the target audience and where you intend to link it to the HCP portal and what that section will house. When not submitted at the same time, it may be possible that changes to one site will impact the other. This will be addressed during the review process of the second site. However, the more information and clarity that can be provided upfront on the relationship/interaction of the two sections, the lower the chances of this become.
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Thank you @jennifer-carroll.
Our client is wondering if it would be relevant to submit the corporate section to PAAB as it would be a basic corporate pharma website (storytelling of the company, product portfolio with PMs, and contact info) for a general audience in Canada?
The HCPs portal would be accessible through a big button on the corporate website's header (and direct link). -
Hello @mbeauclair
At minimum we would suggest getting an opinion. It’s likely that it will still require review. The Distinction Between Advertising and Other Activities document states:
A corporate message is a communication (such as a website, brochure, published article, prospectus or annual report) that gives information about a health product manufacturer or organization. This information could be on the philosophy, activities, product range (by name), financial details and/or area of future development or research.
Corporate messages, or information disseminated through corporate messages, may be considered promotional if:
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they seem to provide information about the health products being marketed, developed or researched rather than the manufacturer or organization
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there is far more information about the health product being marketed, developed or researched than simply its name and the therapeutic area
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in the case of unauthorized drugs or an unauthorized indication, there is no mention that the product's safety and efficacy is still under investigation and that Health Canada has not yet granted market authorization
Additionally, when you link advertising to “non-advertising” it renders everything advertising. If promotional pieces drive users to the site, or the site is used to drive users to the promotional HCP space, it may be considered advertising. This can be assessed in an opinion review.
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@jennifer-carroll Thank you!
