705 - Can a non promotional website that is not subject to review and is only available to verified Canadian HCPs link to a post-gate landing page for a PAAB approved branded website?

  • Let’s assume that “non promotional website that is not subject to review” is referring to a 3rd party website that has a verification process in place to restrict access to HCPs. In this scenario there are two main considerations. Is there an issue linking the branded/unbranded website and is it acceptable to bypass the gating mechanism on the branded website. With respect to the websites, the unbranded website content would need to be acceptable in the context of the brand product, otherwise the link may contravene advertising regulations. With respect to the gating mechanism, if the unbranded site has a valid verification process in place, the HCP is not required to validate their identity a second time. However, keep in mind that the HCP must be directed to the landing page with the respective fair balance copy to ensure they are exposed to the appropriate level of safety information.