558 - If we are developing a postcard with a link to a patient education website on it (website will go through ASC approval) that is designed for the sales rep to give to an HCP to give to their patients, will PAAB have to review the entire website who's link is on the card? The website will have nothing brand specific, it will display all treatment options for patients, however it will have the company logo on it. Thanks!
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Patient information, whether branded or unbranded, which is provided via the healthcare professional is subject to the PAAB code (See PAAB code section 1.1). The postcard is intended to be distributed to patients by the HCP and therefore requires PAAB preclearance. PAAB requires that websites controlled/influenced by drug manufacturers included in APS containing the PAAB logo undergo preclearance by an agency recognized by Health Canada for providing advisory opinions relating to DTCI Rx (i.e. PAAB or Ad Standards). The website content in this case has been reviewed by Ad Standards for adherence to provisions relating to consumer information. There is generally no need for PAAB to re-review consumer information because patients are being directed to it. However, the PAAB will require to review the linkage between the postcard and the website. As such, the website will need to be provided to PAAB as part of the postcard review.
