712 - We have an online newsletter where we post healthcare-related information, as well as society news pertaining to our association. Our member and supporter base primarily consists of hospital pharmacists as well as a small number of architects, students, and pharmaceutical companies. We can set-up advertising on the site to require a login to limit access by the general public. My concern is with the students who are not yet healthcare professionals, the pharmaceutical organizations, and the small number of architect members. Would their exposure to pharmaceutical advertising go against PAAB standards, even if we include a disclaimer that the advertisements are meant for healthcare professionals only? When we used to have...
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continued ... a print journal that contained advertising for pharmaceutical products, the same individuals would have received copies of it. To my knowledge, this was not an issue in the past. However, we would appreciate some guidance to ensure we are being PAAB compliant, as online advertising is new to our association. Thank you kindly.
Response: The regulations that are applicable to your question emanate from Health Canada rather than the PAAB. In other words, the question in this case should be are you Health Canada compliant rather than are you PAAB compliant. Nonetheless, we can provide an advisory opinion on the matter. It sounds as though the publication does not target Healthcare Professionals specifically. As such, the consumer advertising regulations set the boundaries for which ads are permissible in the publication. These regulations differ based on the Federal Drug Schedule of the product being promoted. As an example, direct-to-consumer advertising for prescription drugs is limited to name, price, quantity and direct-to-consumer advertising of narcotics is prohibited. These regulations apply to both digital and print pieces.
