Fair Social Media Practice Principles: Rules for Third-Party Engagement in Patient/Physician Social Networks

Recently, there's been some discussion on Twitter and certain blogs about Sermo, the online physician community based in the U.S. When Sermo representative Thomas Rines (@tomrines) tweeted that "Sermo is an online community for US physicians. We provide our clients the ability to engage with the community" in a recent #MedDevice chat, he caused a "What? Wait!" doubletake (see "The Twitter Chat that Killed Sermo").

It seems that many physicians -- including some who are Sermo members -- are not aware of Sermo's business model, which is “Sermo is free to practicing physicians. Revenue is generated as healthcare institutions, financial services firms and government agencies purchase Sermo products to access this elite group of practitioners.”

Here were some responses to Rines' tweet:

"Sounds like @SermoTeam is willing to host docs for free in order to gather info and push products for $"

"Do docs really know their conversations are being mined?"

"I doubt docs know exactly how Sermo mines their conversations."

"Seems many topics of late come back to transparency & the motives for not being transparent."

"May be a blog post to be had from this."

The last two comments are relevant to why I am writing this blog post.

Before I proceed, you should know that Sermo is a client of mine. I recently helped them promote their services to the subscribers of Pharma Marketing News, most of whom are interested in accessing Sermo's  elite group of practitioners (see the message I sent out to subscribers here: "Get $3,000 of Market Research, FREE"). I've also had a conversation with Daniel Palestrant, Founder and CEO of Sermo, about how pharmaceutical companies can interact with Sermo members (listen to the podcast: "Pharma, Physicians, and Sermo: A Social Media Win-Win-Win!").

I have also wondered how happy Sermo physicians are with its policy and whether or not a majority of them approve of it (see "Pfizer has a Gold Mine in Sermo!").

Given all the publicity and transparency about Sermo's business model, I am surprised to see comments like the ones above and this one by "SteveBMD," author of blog "Thought Broadcast," who said (see "Discussing social media with physicians on Sermo"):

"Sermo is not a physician-only community," says SteveBMD.

"Sermo generates revenue by selling access to its site to “healthcare institutions, financial services firms and government agencies.” See this link on their site: http://sermo.com/client/research/overview

"Unfortunately, this is not made clear to doctors when they sign up or participate. Instead, doctors are led to believe that this is like an “online doctors’ lounge.” A better description would be a doctors lounge with insurance companies, pharma companies, market researchers, and government agencies peeking through the window."

I am not a physician, so I cannot join Sermo and look at exactly what Sermo leads doctors to believe when and after they join. But I do know that Sermo has a 4,278 word "Terms of Use" document that it links to right on the Sign Up page (see below; click for an enlarged view).

This is a typical legal agreement that most of us see on Web sites, but automatically FAIL to read! If you want to become a member, you MUST agree. But what exactly are Sermo members agreeing to?

The Sermo Terms of Use document gets to the point of this blog in ITEM #7, which explains "Hotspots", which are "visual indicators within the Site that enable Sermo and its clients to present opportunities ('Opportunities') for interaction with You." Further down in ITEM #16, Sermo explains that "any material, information or other communication You transmit or post to the Site or third party site will be considered non-confidential and non-proprietary" and "Sermo and its designees will be free to use for any purpose, copy, disclose, sell, distribute, perform, incorporate and otherwise use the Communications and all data, images, sounds, text, and other things embodied therein for any and all commercial or non-commercial purposes to the extent permitted by applicable law."

OK, so Sermo DOES explain its business plan in its Terms of Use.

I question whether this is ENOUGH, considering that most everyone ignores these documents written in legalese -- a language that repulses many of us ordinary folk, including doctors!

Instead, owners and operators of online discussion sites -- whether they be independent corporations such as Sermo, or hospitals, other healthcare organizations, and even pharmaceutical companies (someday) -- should publish SOCIAL MEDIA POLICIES that are separate and different from their Terms of Use agreements.

A Social Media Policy is not just an agreement that users must abide by. More importantly, it is a PROMISE to users from site owners/sponsors concerning how they will protect or attempt to protect user-generated content, personal conversations, interactions, and engagements with third-parties on the site. The policy should also explain how users should "behave" on the site (eg, "rules of engagement").

Fair Social Media Practice Principles
It used to be that privacy policies were written in legalese incorporated into terms of use agreements. Even when separate privacy policies were developed, they varied from site to site owned and run by the same organization. After government (ie, FTC) privacy policy guidelines and laws were enacted, privacy policies were required to comply with standard fair information practice principles that make certain promises about protecting a user's privacy (see, for example, "Pharmaceutical Compliance with Fair Information Practice Principles"). Privacy policies also have become much easier to read and understand.

The same should be true of the social media policies I am talking about. I hope, however, this is done on a voluntary basis by the industry rather than by new laws.

Therefore, in summary, I propose that owners and operators of online discussion sites -- whether they be independent corporations such as Sermo, or hospitals, other healthcare organizations, and even pharmaceutical companies (someday) -- publish SOCIAL MEDIA POLICIES that comply with as-yet-to-be-determined "fair social media practice principles."

But what are the essential elements of "Fair Social Media Practice Principles?"

That's the question I plan to address at a June 22, 2011 workshop in Paris at the Doctor's 2.0 & You conference. Find my workshop on the agenda here.

Some ideas for essential social media good practice principles include:

• A comment moderation policy that explains how discussions are reviewed before or after publication
• Qualifications for discussion moderators, if there are moderators
• How site moderators are trained regarding policies
• Rules for participation in discussions by site owner employees
• Rules for participation by third-party sponsors, clients or their agents
• How "misinformation" is defined and what the policy is for correcting such information

Survey
What do you think? Please give me your input on  this by responding to my Rules for Pharma Engagement in Patient/Physician Social Networks survey. It will only take 5 minutes. I promise that when I get back from Paris, I will write up what I learned from this survey and from workshop participants in Pharma Marketing News. Your responses can be confidential (ie, anonymous) or you can opt in to being cited in the article should I publish your comments.