137 - Would there be an issue with an online banner ad that is exempt from PAAB review linking through to a PDF of the products' Product Monograph?
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I will assume that the proposed banner meets exemption criteria (e.g. a name-only ad). There should not be an issue linking such banner to the complete/unedited product monograph in a website gated for health care professionals however, linking a name-only banner ad to the TMA renders it non-exempt from preclearance as this constitutes a link to therapeutic messages.
In a non-gated site (i.e. accessible to consumers), linking the product monograph for a prescription drug to advertising for that product would contravene section C.01.044 of the Food and Drugs Regulations (even if the ad itself does not go beyond name, price, and quantity). It is important to note that although the complete/unedited product monograph does indeed go beyond the name/price/quantity, it is not considered advertising unless it is somehow linked to advertising. Please call the PAAB office if you need further guidance on this matter.
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@Jennifer-Carroll Hi Jennifer, I was testing the hyperlink above but I get an error message. Not sure if it's because it's a feature that is not ready yet or if it is because it needs a space after the period.
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@NatBourre Good catch. The hyperlink was an error. We have revised the content now. Thank you.
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@jennifer-carroll Hello! Is your answer the same if the banner itself is placed on a gated website, like a gated medical news site? Could we then send these HCPs directly to our content post-gate on our website, since they are already validated HCPs and since our content is already PAAB approved? thank you
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Hi @ramy
The original question was for an exempt APS and if there was an issuing linking to the PM. If it was linked to the PM, the ad is no longer considered exempt. As a PAAB reviewable APS, we likely would not object. The answer remains the same when applied to the scenario presented, i.e. the exempt APS is no longer exempt when it links to post gate PAAB approved content. However, as a PAAB reviewable APS, we may not object to this linkage if the content is acceptable.
