Yesterday, I challenged Pfizer to show us its "Social Media Playbook" that it has been promoting for months at industry conferences (see "Pfizer, Show Us Your Social Media 'Playbook'").
Today, I received a policy document from a credible anonymous source that may just be a version of the authentic playbook. You can find the PDF version of this document here.
[Like all good "leakers," my anonymous source had a motive for leaking this document to me: "I hope the info is helpful to make SM a more acceptable form of employee/customer expression and that large companies shrug off the fear that is currently associated around this platform." I am not sure this document will help ease those fears or substantiate them. See my analysis below.]The document includes two sections of interest to me:
- Additional Rules Applicable to Pfizer-Sponsored Social Media, and
- Any Pfizer-Sponsored Social Media Activities Regarding Pfizer Products Are Promotional Materials Subject to Appropriate Review.
The first section mentioned above includes this:
"Pfizer-Sponsored external Social Media relating to prescription pharmaceutical products must not permit open fields allowing for real-time publication of user comments or posts [my emphasis]. This prohibition applies to Social Media discussing Pfizer prescription pharmaceutical products as well as Social Media that discusses only disease states and not specific prescription products."Although the document states that "the hallmarks of all Social Media are user-generated content and interaction," Pfizer does not allow Pfizer-Sponsored Social Media projects to use the tools necessary for true interaction... UNLESS moderation can be employed. The document further states:
"Open fields on Pfizer-Sponsored external Social Media relating to prescription pharmaceutical products or disease states may be enabled for moderated comments or posts. If any open fields are enabled, in addition to being screened for adverse events, comments or posts must be moderated and pre-screened prior to publication [my emphasis]."Unfortunately, pre-screening may not be possible on some social media platforms such as Facebook, especially after it implements its new rules on comments (listen to this podcast "Pharma Facebook Commenting Changes: The Final Story").
The third section is short, so I will reproduce it all here:
- Any Social Media activity that discusses a Pfizer product, including pipeline products, requires prior approval from the applicable Product Review Committee, Copy Clearance Committee, or comparable review body or process, and must be submitted to regulatory authorities as required by local laws and regulations. For example, in the United States, posts related to Pfizer prescription drugs or sponsored by a Pfizer prescription drug brand team must be approved in accordance with Pfizer Process Governing Review and Approval of United States Product Team Advertising & Promotional Material, Reg. 08-01, and submitted to DDMAC under Form FDA-2253.
- Social Media relating to Pfizer prescription pharmaceutical products on any external Social Media:
a) must clearly disclose that the communication is sponsored by Pfizer;
b) must be fully consistent with the approved product labeling and with all applicable Pfizer policies;
c) must give a fair and balanced presentation of the benefits and risks; and
d) should appear only in appropriate media which allow for:• inclusion of essential information such as the established name and indication as well as
the important safety information for the product;
• a link to the complete prescribing information; and
• a balanced presentation of safety and effectiveness information with comparable
prominence and readability.
- Any medium that does not allow for this information to be presented may not be used for Pfizer-sponsored product discussions. Any exceptions to this prohibition must be approved by the applicable Business Unit Counsel and Regulatory Law.
[I highlighted the above in bold because this is important. It means that Pfizer prohibits branded tweets. It does, however, leave room for exceptions.]
- Any team considering any Social Media activities discussing products or pipeline products must consult with their Business Unit Counsel, Regulatory Law, and the Global Privacy Office prior to engaging in such activities.