Here's how the branded Tweet looks on Kimball's Twitter Web page:
(Click image for an enlarged, readable view.)In this context -- the racewithinsulin Twitter Web page -- the branded Tweet appears on the same page that mentions the indication -- diabetes -- as well as the side effect, fair balance information; although the latter is written using a mouse-sized, barely readable text font.
However, most Twitter users -- about 67% according to my estimates -- do not use the Web to post or view Tweets. Most of us use third-party applications like Tweetie, TweetDeck, Nambu, and Twitterfeed to view and organize Tweets. The variety of ways by which Twitter can be accessed other than through the Web and cell phones is why the Iranian government has not been able to stop Iranians from using Twitter to reach out to the world.
None of these alternative Twitter access channels includes the background information found on the racewithinsulin Twitter profile page. On the right is what Kimball's branded Tweet looks like using TweetDeck.Ross hopes this Tweet represents a "'safe' (and hopefully FDA friendly) approach." This prompted me to take a FDA inspector's view of the Tweet.
On first glance, this looks similar to the Google Adwords cited by FDA in the infamous 14 letters it sent to pharmaceutical companies back in April (see "The 14 Letters. Who at the FDA Knew What and When?").
The difference, however, is that this Tweet does not mention any benefits -- it's essentially what's called a reminder ad, which is not required to include side effect information because it does not mention any benefits. The FDA does not regulate reminder ads, and it is not likely to cite this Tweet as violative.
However, PhRMA's DTC Advertising Guiding Principles preclude this kind of ad on TV: "DTC television advertising that identifies a product by name should clearly state the health conditions for which the medicine is approved and the major risks associated with the medicine being advertised."
Unfortunately, like the FDA, PhRMA has not gotten around to developing Guiding Principles for Social Media DTC Advertising.
A reminder ad of any sort -- whether in print, TV, Web, or Twitter -- is, IMHO, a form of spam. I consider, therefore, Kimball's unabashed product endorsement Tweet a particularly sleazy example of Twitter spam. We certainly do NOT want to see more Tweets like this and I disagree with Ross; I sincerely hope that this Tweet is NOT used as a "model" for other drug companies who want to adopt Twitter as a marketing vehicle.
P.S. Aside from the sleaze aspect, this promo missed an opportunity to educate readers about Levemir. Instead of linking to the product Web site, where you can find some useful information, it links directly to the PDF version of the package insert (PI), a technical document suitable for physicians but not for consumers, which comprise most of Kimball's "huge" audience of 128 followers, none of whom is likely to read the Tweet or the PI it links to!
Interesting post - but I disagree on your assessment that this is spam.
ReplyDeleteReminder ads through Twitter aren't spam, they're just poor marketing that doesn't take the etiquette of the channel into consideration.
True Spam results in persistent, unsolicited messages the recipient has no control over. Your accounts are on lists and you cannot get them off. Senders persistently use methods to bypass filters. Typically, the messages are misleading or fraudulent.
On Twitter, you can simply stop following the creators of unwanted messages. If the sender is being persistent, misleading, annoying, fraudulent, etc. the recipient is in complete control. In those cases, senders lose their audiences and become irrelevant.
Phil,
ReplyDeleteThanks for you comment.
I am quite familiar with the literal/legal definition of spam. I was using the would to figuratively describe how I feel when I receive such a message.
When I signed up to follow Charlie Kinball, I thought I was going to get some great tweets about racing or how he deals with diabetes, not ads about specific products.
While we may have a technical argument about what is and what is not spam, consumers have a much broader definition than you or I.
For example, a few subscribers to my newsletter -- who have DOUBLE-OPTED to receive ads as a condition of their free subscription -- still report my ads as spam although I fulfill all the legal CAN-SPAM requirements!
Ideally, I would not like this to happen and I am looking more carefully at the messages I send to subscribers to make sure they are as relevant and informative as possible.
This, as you suggest, is the real problem with this Tweet: it's bad marketing because it has no information AND its not relevant to me. Hence, to me, it is spam.
John
John,
ReplyDeleteGood points... you subscribed as a fan, they used it for sleazy reminder advertising. I buy your figurative case.
Organizations that just don't get the etiquette of the (new) communication channels they choose is that their audiences aren't as captive as they are through more traditional channels.
You also make a good point about the link to the PI not being very relevant to patients. In the very least they should be linking to the site or (if they're worried about regulatory issues) a medguide.
John,
ReplyDeleteYour role as pharma marketing pundit and blogger personality is always appreciated. The lively debates regarding your posts stimulate and educate, and compel us to think about what we do and how we do it in a new and often refreshing light.
Your recent observations regarding Charlie Kimball’s Novo Nordisk-sponsored tweets are a great case in point. Strong feelings have already been expressed on both sides of the issue; seeing as I’m the one responsible for the blog post that started it all, allow me to chime in on this conversation for a moment.
First, I strongly believe that Charlie Kimball’s Levemir branded tweet is far from “sleazy spam” as you assert. The twelfth tweet of Charlie’s completely transparent “day in the life” Novo-sponsored Twitter page, the post merely states that Charlie took his Levemir (much like he announced a live chat a day before, or tweeted about cleaning his race suit the day before that). Yes, the post itself is a bit awkward, but it’s hard to stay colloquial when a regulatory cloud surrounds this kind of communication; inclusion of the generic name and link to the PI were necessary for the tweet to even be possible.
Secondly, as you and most of the visitors to your blog already understand, social media is a vitally important channel for pharma, one that is still under-utilized. Our jobs as pharma marketers is to facilitate its adoption. As Scott Docherty’s official P&G response to your complaints about the Asacol network suggests, the gap between idealized vision and practical execution in the pharma social media space is inevitable given the current regulatory environment. Pharma is doing its best; baby steps forward shouldn’t be shot down because they might appear awkward.
Finally and most importantly, what’s lost in this debate is the value such a Twitter celebrity spokesperson provides to the diabetes community. As a professional race car driver who doesn’t let his diabetes get in the way, Charlie is a living symbol of how a chronic disease can be managed effectively. By following his tweets, Charlie’s 125 and counting followers gain inspiration from a real person with diabetes, nonetheless living life to the fullest. I’ll continue to follow his tweets, and applaud Novo for taking this bold initiative to utilize the capabilities of Twitter to help educate and motivate those living with diabetes.
Regards,
Ross Fetterolf
Ross,
ReplyDeleteThanks for your comments.
Charlie Kimball's Tweets would be much more interesting if he stopped posting about cleaning his race suit, taking Levemir, etc, and told us a little bit about how he FEELs being a race car driver with diabetes, how he deals with the unique problems his medical condition gives him, etc. THAT would truly be inspirational!
The real challenge for pharma marketers is to make a personal connections via social media, not to figure out how to get around regulations to promote brand name drugs.
So my advice, which you are so kind to consider, is to put away the branded hammer and take out the unbranded silk gloves.
John
Call me old fashioned, but isn't this a colossal waste of brain cycles, considering this guy only has 169 followers? Of which, I'd tender a bet that 25% constitute the company and agency behind it?
ReplyDeleteThere are more people in the pit crew.
Of course. I tried to point that out in my closing remarks.
ReplyDeleteHowever, that 6 more followers than he has for his personal account at http://twitter.com/charliekimball
John,
ReplyDeleteI don’t see this as “spam” – if he was only tweeting about the drug and asking followers to click on a link that would be spam. I see people on twitter talking about the products they use and sharing that with followers. I oftentimes will say something about a product I’ve used. I’m no celebrity and no one pays me to say it so I guess that’s the difference.
I think the bigger violation here is the non-disclosure element. I hope that somewhere it says that Charlie Kimball is being paid to tweet about this product.
The first thing that jumped out at me was the fact that Charlie Kimball isn't following anybody - my experience is that the real "magic" of social media is the interaction factor, seeing what others are saying and engaging in the dialog (that's how I ended up at this blog).
ReplyDeleteThat's my 2 cents' worth
Exactly! Even on his personal Twitter acct (http://twitter.com/charliekimball), where he does have followers like me and where he follows people, Charlie does not respond to direct messages -- at least not from me! A very dissatisfying SM experience!
ReplyDeleteAs a person with type 1 diabetes (autoimmune-mediated), I consider this effort Twitter spam without question, and I would likely have removed this guy from my follow list if I got any crap like this. Not only does it not even remotely interest me, but I have lost respect for the endorser, in this case Charlie Kimball. This effort is neither informative nor convincing, and is likely to irritate people who use this social medium, but do little to translate into tangible benefit for Novo Nordisk and could actually damage their reputation).
ReplyDeleteI totally agree with this anonymous post.
ReplyDeleteI consider myself a pharmamarketer and I really understand what does social media is (more than helpfull for marketers) but, just a simple question, Why Do people are on SM, what do they want to have? a real social space in which they can share experiences with similars(the main social media success and a good chance to us) or a space in which a common salespersons wants to make a deal?
Personally, I think we must carefully see which road we are taking right now.
Some marketing efforts can put us in the fire line and not precisely to feel proud of it
Totally agree with SocialMediaWiz.
ReplyDeleteThis is not classed as 'spam'. This is advocacy or endorsement, but it's certainly not 'spam'.
Habitat's 'interngate' was spam.
All Charlie has done is tweet a brand name, he has not tagged his tweet with varying trending topics from that day in an attempt to get the tweet more profile. It is perhaps considered shameless from an endorsement perspective (although we've no guarantees he received remuneration for this action), but advocacy is the growing influencer for consumer decision making these days and any brand that can't recognise that is going to be left behind in the race to the till/prescription pad.
FYI - No-one is likely to respond to DMs when they're not already following that person, particularly when it's likely to have been a message accusing them of spamming.
John, also, in your comment about whether it's 'relevant' to you or not is an odd argument. He does not write his tweets for an audience of 'you'. If you feel his content is not 'relevant' to you then stop following him. Simple.
There are fine lines in SM between what is acceptable for a brand to do and not to do, but this is most definitely not spam in my mind.