649 - Our company has an unbranded disease-focused app in the Apple/Google stores. As legally required, the manufacturers name must be disclosed in these stores. Can we make mention of this app in a separate DTCi Help-Seeking campaign (that itself does not mention the sponsor)? The campaign would not focus on the app, but mention it as one of many additional resources.
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The Health Canada document “Distinction Between Advertising and Other Activities” states that materials that fall in the category “Help Seeking Announcements” must not include the manufacturer’s name. PAAB interprets that to mean that the piece must not identify the manufacturer by any means. Providing a direct link to a corporate branded asset would identify the manufacturer. In your specific case, I have no way of knowing whether your piece is indeed a help-seeking announcement (for which this linkage issue would apply). Nonetheless, a simple solution exists if that is the case. You could direct the public to the app using corporate advertising as opposed to a help-seeking message. E.g. Company X created an app with features A, B, and C for patients with condition Y. This app can be downloaded at the app store: Click here. We are committed to helping you. You’ll note that I left out content relating to how a patient might know if he/she is afflicted with condition Y (e.g. symptoms, history…). I focused instead on the service that this company is providing to individuals afflicted with the condition through provision of the app. I should also point out that there is an important exception to the linkage issue I discussed above. A help seeking announcement may link to a document meeting all requirements of a consumer brochure. This is true even though the consumer brochure will identify the manufacturer. In that instance, the reader would learn about the identity of the manufacturer in the same context that he/she is exposed to presentation of the treatment options (drug and non-drug) and their respective risks and benefits discussed in an objective manner.
