I am following the results of this survey closely and will provide updates. Here, I focus on this question:
How should companies disclose their involvement or influence over discussions or material, particularly discussions or material on third-party sites?The survey asks respondents to choose one or more of the following responses (and add additional comments):
- Disclosure is necessary only when content is paid for.
- Disclosure should be prominently displayed alongside relevant content when possible
- Disclosure and disclaimers should be included prominently on the corporate website near any links to social media outlets.
- Each company should have a public SM policy that includes a notice of its transparency policies.
- None of the above
Many comments were submitted in response to this question. Some of these comments include:
- We can't make rules/laws for everything. It would be better to hold companies responsible to their stakeholders - investors, customers, patients, healthcare professionals, etc etc.
- Disclosure and disclaimers should be included prominently on the corporate website near any links to social media outlets.
- When companies pay for content to be produced on their behalf, a disclosure, disclaimer and list of policies should be included prominently on the corporate and associated websites near any links to social media outlets.
- A notice of disclaimer should be provided whenever there is a content favorable to the company's interests that has been elaborated directly or indirectly by any third-party benefited by the company.
- Disclosure must be constant, no exceptions; even Twitter comments must contain disclosure, even if in the form of a hashtag (#iwork@novartis is in use today)
- If true: "We encourage our employees to message about their experiences with our products, but they are not separately compensated for these messages. You should consider whether opinions being offered here are from a source whose employment is tied to the maker of the product being discussed."
- If company involved, should always disclose. In scenario where a brand has sponsored some activity, could disclose pharma company involvement without mentioning the brand name, not as a way to cover up brand involvement but to avoid using brand name and triggering need for fair balance.
SPECIAL REPORT: FDA Regulation of Social Media
Find links to more preliminary results here.
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