633 - I would like to send an email to verified healthcare professional, that email would not exceed Price, Name, Quantity, would include no claim and have a deep link to access the product monograph of this schedule A product. Do I need to submit such email to PAAB approval if ... 1- the product monograph is only accessible via this email ? 2- the product monograph is hosted on our corporate website (ungated website) ? 3- the product monograph is hosted on a gated hcp website ?
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I will assume that the proposed HCP email meets the exemption criteria per section 1.5D of the PAAB code. The question then becomes, do any of the proposed links render this content subject to PAAB review. There should not be an issue linking an exempt email directed to healthcare professionals to the complete, unedited product monograph. This applies whether linking to a product monograph on the corporate website or on an HCP gated website. The key message here is that to remain exempt from PAAB review, it must be a direct link to the product monograph.
