AUTH/3248/9/19 - Voluntary admission by AstraZeneca


  • Received
    30 September 2019
  • Case number
  • Applicable Code year
  • Completed
    07 February 2020
  • Breach Clause(s)
  • Sanctions applied
    Undertaking received
  • Additional sanctions
  • Appeal
    No appeal
  • Review
    To be published in the Review

Case Summary

AstraZeneca UK Limited voluntary admitted that one of its employees had used his/her personal Twitter account to re-tweet nine tweets about Forxiga (dapagliflozin) and one tweet about Lynparza (olaparib). Forxiga was indicated for use in adults with insufficiently controlled type 2 diabetes. Lynparza was indicated for maintenance and treatment of certain cancers.

As Paragraph 5.6 of the Constitution and Procedure required the Director to treat a voluntary admission as a complaint, the matter was taken up with AstraZeneca.

AstraZeneca explained that the original tweets about dapagliflozin were posted by health professionals following a presentation of clinical trial data (DAPA-HF study) at the European Society of Cardiology (ESC) in Paris. The data from that presentation was not currently within the licensed indications for Forxiga. The original tweets were re-tweeted on a personal Twitter account by a UK-based employee of AstraZeneca’s global organisation. The re-tweets had subsequently been deleted.

It was further discovered that the employee’s Twitter account contained a tweet about Lynparza which was subsequently deleted.

AstraZeneca stated that it had reminded employees globally and reinforced that product-related content (including study results) were not allowed on employees’ personal social media channels. AstraZeneca submitted that it had a clear policy on the use of personal social media with respect to company related content.

The detailed response from AstraZeneca is given below.

The Panel noted that the original nine tweets about Forxiga posted by health professionals concerned the use of the medicine in heart failure. The posts were re-tweeted by a UK-based AstraZeneca global employee using his/her personal account. In the Panel’s view, the re-tweets had to comply with the Code.

The Panel noted that all of the re-tweets were positive about the results for dapagliflozin in heart failure in patients with or without diabetes.

The Panel noted that the employee’s Twitter followers included both health professionals and members of the public.

The Panel considered that the re-tweets promoted Forxiga for an unlicensed indication and advertised a prescription only medicine to the public. Thus the Panel ruled breaches of the Code as acknowledged by AstraZeneca.
The Panel considered that the re-tweets should have been certified prior to use. AstraZeneca acknowledged that the re-tweets had not been certified and a breach of the Code was ruled.

With regard to the tweet about Lynparza, ‘AstraZeneca’s Lynparza gets EU nod as first-line ovarian cancer maintenance treatment’, also re-tweeted by the same AstraZeneca employee, the Panel considered that it also advertised a prescription only medicine to the public and had not been certified prior to use. Breaches of the Code were ruled. The Panel noted that the indications for Lynparza in ovarian cancer appeared to be second line ie in patients who were in response to platinum-based chemotherapy. The Panel considered that the re-tweet promoted an unlicensed indication and a breach of the Code was ruled.

The Panel was mindful of the complex issues that had to be addressed by companies when advising staff about social media use. The increasing use of social media, both in the personal and business capacity, presented compliance challenges. It was therefore critical that companies provided clear and tailored guidance for employees which was regularly reviewed.

The Panel noted that the employee in question was trained on the Global Standard: Social Medica Personal Use in January 2018, however updated versions of this standard (February 2018 and August 2019) had not been ‘read and signed’ by the employee. AstraZeneca explained that technical issues relating to the use of a new template resulted in the employee not receiving an automated version update in his/her training account. The Panel noted, however, that the employee was alerted to the availability of the updated guidance via a number of other channels.

The Panel noted that in a series of company announcements in August 2019 to coincide with the release of the latest version of the Global Standard it appeared that AstraZeneca employees were positively encouraged to post certain work-related content on their personal social media accounts. This was reinforced by the use of phrases ‘Empowering you to bring our unique culture to life on social media’, ‘When can I post work-related content on social media’ followed by four questions to consider to ensure compliance with the Global Standard and finally ‘Good to go! Can’t wait to see your posts’. The items listed as appropriate to post included, inter alia, ‘Is it about scientific advancements?.’ The Panel considered that following this company announcement it was possible that the employee had decided that the tweets related to scientific advancements and therefore re-tweeting was encouraged. It appeared to the Panel that although the announcement related to the same Global Standard issued in August 2019, the content had been presented very differently in the announcement.

The Panel noted that following notification of the dapagliflozin related re-tweets AstraZeneca posted a reminder to employees about its social media policy including a link to the document via its internal social media platform. A second reminder to employees in September, following identification of another product-related re-tweet by the same AstraZeneca employee, set out three things to watch out for when posting content on personal social media. Firstly, was the material product-related or about disease education/awareness, secondly was it confidential and thirdly did it contain personal data about others that you did not have consent for. If the answer was yes then staff were told not to post it.

The Panel considered that it might be difficult for some employees to balance the positive endorsement from AstraZeneca to post certain work-related content and the need for employees to make a judgement about what they may post.

The Panel noted its comments and rulings above and considered that high standards had not been maintained by AstraZeneca; a breach of the Code was ruled.