When must PAAB review DTC materials?
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Hi there!
We are creating a gated, branded website. The pre-gate landing page will have content that is appropriate for a DTC audience. From that pre-gate landing page the user could login as an HCP or a patient. This website will be submitted to PAAB for review.
Our client would like to create banner ads which will exist in the DTC space that drive to the pre-gate landing page of the PAAB-approved website. The ads will target HCPs but appear in DTC spaces online so we understand that the content needs to be appropriate for a DTC audience since we cannot confirm 100% that only HCPs will be exposed to the ads. The content of the ads will simply be "BrandName: Now Approved in Canada. Visit BrandName.ca.".
I have 2 questions based on the above:
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Do the banner ads need to be submitted to PAAB for review and approval? Or could they be submitted to ASC since they are DTC ads?
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If we do submit the ads to ASC for review, do we need to notify PAAB of the ASC-approved banners ads that link to the PAAB-approved pre-gate landing page?
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Hi @maryssa
From the description in the question, the ads are visible to the general public but they are designed for HCPs. As such, the primary audience are HCPs and the general public is the secondary audience. Consequently, the provisions of the PAAB Code apply, including the need for PAAB Preclearance. Because of the secondary audience, our assessment would also include the need to adhere to federal regulations pertaining to consumer advertising. Please ensure the submission letter conveys that the banner ad will be placed in pre-gate environments.
