Gating Requirements
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If a company executes an unbranded campaign (the campaign can’t be liked, commented or shared with others) on LinkedIn and only targets people who in their profile indicated that they are an HCP is that ok? If yes, and the individual clinks through to a company sponsored website, does the company need to do a verification on its website that the person is an HCP? If someone falsely indicated on LinkedIn that they are an HCP, they are in breach of LinkedIn policy as well.
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Hello @starship1
Please keep in mind that it is the sponsor’s (manufacturer’s) responsibility to ensure a robust validation mechanism for gating access to information that is intended for Canadian HCPs. An individual self-declaring that they are an HCP (without any additional verification) is not considered a valid gating mechanism. LinkedIn does not validate users’ information and therefore cannot be used as a mechanism for validation. It may be possible to target unbranded content to HCPs on LinkedIn, however it would require a dual review for a DTC audience and an HCP audience as the users would not be validated. In this case, any “linked” content which exceeds the consumer regulations would still require the user to be validated as an HCP. See the document Guidance on Gating Mechanisms for Healthcare Professional Targeted Digital Assets.
