Unauthorized Use of Content on this Site: The responses, guidance, and advisories provided by the Pharmaceutical Advertising Advisory Board (PAAB)—including, but not limited to, those available through the PAAB Forum, the PAAB website, and any PAAB correspondence—are specifically intended to assist individuals navigating the PAAB preclearance system. Repurposing or reproducing this content, or using it for model training or any related purposes, is strictly prohibited without the express prior written consent of PAAB. This includes, but is not limited to, the use of such materials in automated systems, machine learning models, or artificial intelligence applications.
556 - Hi PAAB, Section 1 of the Code provides that it applies to APS directed to HCPs (as well as patient information distributed via HCPs). Corporate websites target consumers rather than HCPs. However, it seems that PAAB considers corporate websites presenting information on the company's products as corporate APS (s. 7.4 of the Code) that must be submitted to PAAB. Does it mean that the Code also applies to material that does not target HCPs? If the corporate website presents general information on a disease or a class of products, does it need to be submitted to PAAB or would it be considered as DTCI? Thank you.
-
A non-gated corporate website is intended for the general public and would be subject to the consumer federal regulations, not the PAAB code (assuming that you are not somehow linking HCP advertising to particular pages of the corporate site other than the home page). The PAAB offers an opinion service for DTC pieces including institutional messages. The Health Canada document "The Distinction Between Advertising and Other Activities" is used as the basis of this assessment.A consumer facing institutional message is a communication which provides information about a pharmaceutical manufacturer concerning topics such as its philosophy, activities, and product range. There must be no emphasis on one or more products. The central purpose must clearly be to inform broadly about the institution rather than its products.If the corporate message is directed at Healthcare professionals, PAAB Code section 7.4 should be applied.
