Social media guidance
The PMCPA cannot approve any materials or activities, it can only give informal advice based on its interpretation of the Association of the British Pharmaceutical Industry (ABPI) Code of Practice (“the ABPI Code”). In the event of a complaint being received about any matter referred to in this document, it would be considered in the usual way; the Code of Practice Appeal Board would make the final decision if a case went to appeal. Each complaint is considered upon its own merits and based upon the allegations raised by the complainant. This guidance has been developed and revised by the PMCPA following collaboration over several years with various stakeholders, including the MHRA, the ABPI and pharmaceutical company representatives. This guidance reflects the PMCPA’s current interpretation of the relevant UK legal framework, the requirements of the European Federation of Pharmaceutical Industries and Associations (EFPIA) and the International Federation of Pharmaceutical Manufacturers and Associations (IFPMA), and the ABPI Code. It also reflects the PMCPA’s views based on available case precedent. As with any guidance, it does not replace the need for pharmaceutical companies and their personnel (including members of staff, those retained by way of contract and third parties) to follow the ABPI Code and all other applicable codes, laws and regulations to which they are subject. It also does not identify all the requirements that must be followed for each activity, as they may vary significantly depending on the nature of the activity. The guidance is split into sections for ease of reference. However, each section is not intended to be read isolation - important context will appear within other sections, including but not limited to the principles and responsibility sections.
This section of the guidance will cover:
• What is social media?
• What are the fundamental principles that pharmaceutical companies should consider when using social media?
• What other rules and regulations should be considered when using social media?
• Key questions to consider before carrying out any social media activity
Social media principles
This section of the guidance will cover:
• Who is responsible under the ABPI Code for social media activity?
• When does social media activity outside the UK fall within the scope of the ABPI Code?
Responsibility
This section of the guidance will cover:
• Creating content: links, hashtags and tagging
• Interacting and engaging with social media content
• Targeting social media activity and closed communities
• Monitoring comments and meeting pharmacovigilance responsibilities
• Responding to misinformation or inaccuracies
• Creating a personal profile
Types of activity
This section of the guidance will cover:
• Signposting information or directly communicating?
• Promotion to health professionals and other relevant decision makers
• News and announcements suitable for the general public
• News and announcements for an investor audience and the media
• Does the prohibition on medicine name in a post apply to investigational compounds with no INN?
• Disease awareness for the public
• Patient support
• Job adverts
• Clinical trial recruitment
Types of content
This section of the guidance will cover:
• Working with influencers
• What should companies put in written agreements with third parties in relation to disease awareness campaigns on social media?
• Declarations of involvement for sponsored events and materials
Working with othersPMCPA social media guidance
Enquiries should be sent to info@pmcpa.org.uk