Skip to content
  • Categories
  • Recent
  • Tags
  • Popular
  • Users
  • Groups
Skins
  • Light
  • Cerulean
  • Cosmo
  • Flatly
  • Journal
  • Litera
  • Lumen
  • Lux
  • Materia
  • Minty
  • Morph
  • Pulse
  • Sandstone
  • Simplex
  • Sketchy
  • Spacelab
  • United
  • Yeti
  • Zephyr
  • Dark
  • Cyborg
  • Darkly
  • Quartz
  • Slate
  • Solar
  • Superhero
  • Vapor

  • Default (No Skin)
  • No Skin
Collapse
Brand Logo

Forum

  1. Home
  2. PAAB Q&A
  3. DTCA/I, consumer secondary audience
  4. 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.
PAAB Notice
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 correspondences, are specifically intended to assist individuals navigating the PAAB preclearance system. Repurposing or reproducing this content without written consent from the PAAB Commissioner is strictly prohibited. This prohibition includes, but is not limited to, use in machine learning or AI models.

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.

Scheduled Pinned Locked Moved DTCA/I, consumer secondary audience
1 Posts 1 Posters 1.0k Views
  • Oldest to Newest
  • Newest to Oldest
  • Most Votes
Reply
  • Reply as topic
Log in to reply
This topic has been deleted. Only users with topic management privileges can see it.
  • Jennifer CarrollJ Offline
    Jennifer CarrollJ Offline
    Jennifer Carroll
    wrote on last edited by
    #1

    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.

    1 Reply Last reply
    0
    Reply
    • Reply as topic
    Log in to reply
    • Oldest to Newest
    • Newest to Oldest
    • Most Votes


    • Login

    • Don't have an account? Register

    • Login or register to search.
    • First post
      Last post
    0
    • Categories
    • Recent
    • Tags
    • Popular
    • Users
    • Groups