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168 - For our Vaccines web sites which are branded, we would like to include a link to our unbranded Digital Video News Release (DVNR) which will be housed on YouTube. We are also considering storing a PDF version of our unbranded matte stories on the website. Is there any concern with placing unbranded materials on a branded web site? Does it matter if it is a Vaccine or Rx product?
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With respect to your specific questions, the main concern with placing unbranded materials on a branded web site is that you would be linking the unbranded content with the brand (i.e. this could essentially "brand" the "unbranded" content). There are multiple implications to this (and this is where the federal schedule of the product comes into play as per your second question): Advertising for all products (whether Rx or vaccine) must be in accordance with the Terms of Marketing Authorization granted by Health Canada . If the disease content on the video extends beyond the indication of the product featured on the site, the sponsor may be violating section 9(1) of the Food and Drugs Act. Specifically for websites promoting an Rx product or a product indicated for the treatment of a schedule A disease, there is an additional concern. The consumer accessible portions of such websites should not link the product to its therapeutic use. An unbranded disease video may do this. The PAAB can help you get it right through the preclearance review program and/or opinion advisory for DTC advertising. You should familarize yourself with the "Press Releases" section of the Health Canada document "The Distinction Between advertising and Other Activities" because your You Tube DVNR site may not meet all of the requirements of an exemption for advertising.
