Messaging in email signature used for 1:1 communication
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Would it be possible to add a partnership message to an email signature used by Brand Managers to communicate both internally and externally (which would potentially include HCPs, patients, vendors, etc.). For this example, the partnership message would not indicate the category or indication but some of the company's products by name along with a commitment message.
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Linking a message to an email signature used by Brand Managers has the potential to have implications for the product/brand, so it would depend on what the actual “commitment message” is. The following are just general principles to consider for different target audiences:
When directed at a non-HCP audience, Brand Manager sign-offs should meet the applicable DTCA regulations (e.g., name/price/quantity for Rx and no mention if narcotic or controlled substance, for the totality of the message in the communication).
With respect to HCP communications, the PAAB Code should be considered. Code section 1.5E states that to be considered an exempt corporate message there should be no product mention. In addition to product mention, “commitment message” is vague and could easily become problematic. This type of addition to signatures would likely render the piece reviewable. Additionally, note that a 1:1 communication is exempt on the predication that the user has requested the information in an unsolicited manner and that the information being provided is done to address the specific request, not to provide additional unsolicited content (e.g. “commitment message”)
We would also question brand managers messaging patients and note that patient information cannot be promotional in nature.
