637 - We are currently embarking on a help seeking announcement for a prescription product. The help seeking message will follow the criteria as outlined in Health Canada's policy, The Distinction Between Advertising and Other Activities. We wish to additionally inform HCP’s of this campaign through promotional systems such as a detail aid to ensure full transparency to the HCP regarding the campaign. • Are we able to identify the help seeking campaign in promotional systems directed to HCPS? • Are we able to include additional promotional product messages in the promotional material? • If not permissible in the same promotional system, are the two allowed in the same sales call?
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A tool meeting the requirements of a help-seeking announcement as outlined in the Health Canada policy document “The Distinction Between Advertising and Other Activities” is not considered to be promoting the sale of a drug and therefore is not subject to advertising regulations. However, informing HCPs of the help seeking campaign through the use of promotional systems or activities (i.e. sales calls) creates a link between the non-promotional help-seeking content and the promotional advertising campaign. This would render all content subject to the advertising regulations. The help-seeking message for consumers would have to be unbranded. If communications to an HCP created a link between the help-seeking message and a brand, the help-seeking message would have to be reviewed and approved in the context of the brand. If the message did not meet the limitations of the brand, a link could not be made.
