Friday, March 05, 2010

Pharma Should Leave Unmoderated SM Discussions to 3rd Parties

In comments addressed to the FDA, many drug companies and ad hoc industry groups are suggesting ways drug companies can legally "engage" with patients, physicians, and consumers in online social media discussions (see, for example, "A Pharma 'Social Media Working Group' Submits Comments to FDA").

The hope is that new FDA guidelines (or regulations) will help them do that.

Some drug companies imagine the day when they will be able to host open discussions on their web sites -- even drug.com sites.

The question is, under what terms? Specifically, what conversations will they allow and not allow and how will they deal with posts that are "not allowed?" Every social media site has to have a policy regarding this issue.

Once you allow online conversation, you open yourself up to unsolicited commercial posts (ie, spam), posts from disgruntled employees or people with an axe to grind, posts from competitors and their employees who want to bash your products, anonymous posts from your own employees trying to put your product in a better light than is warranted by the package insert, posts from lawyers trying to get a class-action lawsuit going, well-meaning posts by patients spewing misinformation about your products, etc., etc., etc.

Pharma companies are especially prone to these kinds of posts. Believe me, managing online discussions is no walk in the park with your mandolin. It takes a lot of work and attention.

It would take a lot MORE work if every post submitted first had to be reviewed by your legal/regulatory people before it could be published. Naturally, neither the L/R people nor the SM evangelists within pharma want that burden. Hence, pharmacos suggest that posts to their discussion boards should be UNMODERATED. Of course, they say that this is the only way to allow social media to work as it should - uninhibited, free speech.

What pharma wants to do is to moderate AFTER the fact. That is, remove posts that violate the terms of use. This is how CafePharma works. It has a very active community with very many useful discussions. But the pharma industry is not loving it -- there are many posts from disgruntled employees that criticize the industry. These posts are often X-rated.

Of course, this does not mean that discussions on pharma-owned Web sites would degenerate to the level of CafePharma. But, hey, it could happen!

I moderate every comment submitted to this blog before it is posted. Every day I get comments like this one from "marry": "Blogs are so informative where we get lots of information on any topic. Nice job keep it up!!" First of all, it does not add anything to the conversation. But more important, when you click on "marry" you are likely to end up ion a Web site selling something -- probably counterfeit Viagra pills!

Does the industry want its discussion boards filled with that kind of content? Of course not! But their method of dealing with it leaves a lot to be desired. I imagine one designated employee coming in every morning and reviewing the posts made the previous 24 hours and spending an hour or so deleting the ones that violate the terms or commenting on the off-label ones and keeping them around for awhile so everyone can tell it's off-label (some propose deleting these after 48 hours, some do not indicate any specific time limit).

It's all about the FTE devoted to the job -- the less, the better! Moderation before the fact may require too many FTEs. After the fact, it is much more manageable.

But in social media time, 48, 24 or even 2 hours is a long time! Just ask Ray Kerins, Pfizer's head of corporate communications. While he was busy in traffic court, the Twittersphere buzzed and re-buzzed about whether or not @pfizer_news, which was just launched, was an official Pfizer Twitter account! (see "Pfizer's Social Media Strategy: Piss Off John Mack, Get Hundreds of New Followers!")

To paraphrase Omar Khayyam: "The Moving Finger posts; and, having Tweeted, Moves on: nor all your Piety nor Wit Shall lure it back to cancel half a Line, Nor all your Tears wash out a Word of it."

11 comments:

  1. Of course the fact that pharma cos want to have discussions on their brand websites comes as no surprise to me. I did a survey a while back that showed that this was the first tactic marketers would pick if there were no rules (http://www.doseofdigital.com/2009/09/crushing-pharmas-digital-marketing-dreams/).

    Moderated or not to isn't the issue. The issue is that who cares?

    If there's a forum on a pharma brand.com site, why would I participate in that whether it was moderated or unmoderated? As I wrote in my post: "People don’t like pharma companies. Sorry, but you probably knew that. They don’t really trust pharma companies all that much either. Sorry again. So, why on earth do you think they’d want to join your community instead of one maintained by a completely unbiased third party like WebMD? Why? What’s the value? When it comes to a branded community, you simply can’t offer anything they can’t get somewhere else."

    This applies whether it's moderated or not. The reasons why a PKU.com works (pharma owned and unmoderated) is because there is no alternative for PKU. For nearly everything else, there is a neutral, unbiased, 3rd party site where you can have a discussion without "big pharma" looking over your shoulder. Don't you think this is what people would prefer to do? How come pharma companies don't seem to know this?

    General rule of thumb: The only brands that can pull off a brand.com community that has people flocking to it are the same brands that people tattoo on their bodies.

    Jonathan
    Dose of Digital

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  2. The first thing I noticed about the forums on PKU.com is that there are very few posts and most are over two weeks old. I also noticed that there are forum "moderators" although I am not sure how that works because when I clicked on the moderator link I had to first register, which I did. The next thing I noticed was all the personal info that I had to enter just to participate in the forums -- my home address, birth date, age, etc. That alone would stop me from joining this "community" were I a real patient. I did, however, register and I am awaiting the confirmation email, which I have not yet received after about 5 minutes of waiting.

    All in all, not my formula for a very successful SM site.

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  3. P.S. Yeah, I guess I would not have VIAGRA tattooed any where on my body, although....

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  4. Interesting post John. I agree with Jonathan that pharma is always going to be on the back foot with its own forums due to people being wary of commercial bias versus external forums.

    Where I could see it potentially working is for pharma to host disease specific forums, but even these would work better on an external site.

    As an additional point, my view is that some kind of moderation is essential for any forum. It's not about control, but a totally unmoderated forum quickly descends into spam city (as some of the badly moderated Linkedin groups and forums show), which just means people don't go there for sensible debate.

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  5. Posting comments on someone's blog must have relevance to the topic being discussed. There shouldn't be some unnecessary comment included to a certain post for it annoys people who are reading or are part of the said discussion. Obvious spammers usually post their links which are truly not necessarily relevant to which people in the said discussion must click on his link. It's just that they are plain messing or misleading the blog that is supposed to be discussing a certain topic to all of the people involve. In short, they annoy us.

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  6. Posting comments on someone's blog must have relevance to the topic being discussed. There shouldn't be some unnecessary comment included to a certain post for it annoys people who are reading or are part of the said discussion. Obvious spammers usually post their links which are truly not necessarily relevant to which people in the said discussion must click on his link. It's just that they are plain messing or misleading the blog that is supposed to be discussing a certain topic to all of the people involve. In short, they annoy us.

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  7. I personally think it's OK as long as the comment is related to your post. Now if someone comes to your blog and leaves random comments that are not relevant to your post then you should classify it as spam. Otherwise why have a place for people to put there Url?

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  8. FDA has been messing up with us lately. I don't know what they're thinking. Tsk!

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  9. I believe that leaving it on a third party is the best choice. Things like this must not allow pharma companies to hinder their services and exposition to the potential clients. They can outsource the service if they like.

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  10. That would be the day everyone starts prescribing their own medicine or just buy them like candy. What the pysicians are going to do then? Love the image.

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  11. I don't get this image. Is that a Jesus or what?

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