151 - If a pharma company sponsors a direct to consumer information (DTCI) site for Disease Awareness, can it talk about therapies (if they are all discussed equally, both drug and non-drug therapies)? I believe this to be "Yes". Assuming that, can the site also link from the therapy descriptions to branded drug websites as long as it handles all treatments equally?

  • The answer to the first question is "yes" provided all requirements in the consumer brochure section of the Health Canada policy document "The Distinction Between Advertising and Other Activities" are met.We advise against linking various product websites even if this is done in an equivalent manner for all products.Note that:The landing pages on the gated product sites should not be linked to the therapeutic content in the consumer brochure and vice versa. The linkage can be problematic on multiple fronts. For example:With respect to the product site landing page: this linkage would exceed the name/price/quantity restrictions of the Food & Drug Regulations section C.01.044 (as the consumer brochure will discuss the therapeutic area).With respect to the consumer brochure itself: This would link it to reminder advertising (i.e. the landing page prior to the gate). This linkage would compromise the "non-advertising" status of the consumer brochure. According to the Health Canada linkage principle, when advertising is linked to non-advertising, the combined entity becomes advertising.This could confuse consumers as they will keep clicking onto these links only to get to landing pages which don't allow them to go any further than the barrier.

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