Friday, December 14, 2012

Pharma MLR "Social Media Scaredy Cats" Don't Trust Their SM Pioneer Employees

At the Social Media, Mobile & Gaming for Pharma conference in New York City this past Wednesday, a discussion about pharma being "committed" to social media took an interesting turn when an attendee "complained" that "every single word that we say -- every single word -- even the punctuation, has to be approved."

This person handles ALL the social media, including the Twitter account, for her (small) pharma company, which shall go unnamed.

Here's how she tweets: First she writes up a batch of tweets and submits them to her medical-legal-review (MLR) people for review and approval. This takes about a day -- lucky for her she works in a small company; a larger pharma company may take much longer to approve tweets.

What's sad is that this person wrote some tweets to be sent out during the conference she was attending, but she decided that her tweets were no longer relevant after she heard what was being discussed at the conference! Meanwhile, the things she would have liked to tweet about while at the conference, she simply could not tweet about without first getting approval!

This is no way to use social media. First of all, pre-tweeting comments that seem to be in response to a live event or online chat is not a good social media practice. What if someone responded to one of her tweets during the conference? How could she respond back; i.e., have a conversation?

When I heard this, I felt sorry for this pharma social media pioneer. "Your company doesn't trust you! How can you do social media if nobody trusts you?"

But the worst part is that this person feels she has a lot of leeway compared to other people she knows in the pharma industry.

Hey, I understand why pharma companies don't trust certain employees -- i.e., sales reps -- to use social media (see this case as an example). But if you have designated someone as the person to manage your social media communities, surely you have trained that person regarding your social media guidelines. What? You say you don't have no stinkin' social media guidelines? Well, then, shame on you!

In a world such as ours where a world-renowned bank that purposely laundered terrorist and drug trafficking funds can get away with a mere $1.6 billion fine and no jail time, then one single errant tweet made by a trained employee surely can be tolerated as a risk you can live with!

What's the worst that can happen, even if the FDA were to find out about the errant tweet (which I am sure they would not)? In the case of the sales rep mentioned above, the UK Prescription Medicines Code of Practice Authority (PMCPA) ruled that Allergan breached UK pharma's self-regulatory Code of Practice because an employee accidentally tweeted publicly about Botox. PMCA added "The Panel considered that Allergan had been badly let down by its employee." How sweet is that?

Anyway, I believe that many MLR people within pharma are "Social Media Scaredy Cats." It's probably a corporate "ladder" syndrome that goes all the way up to the CEO.

In contrast to the person whose was under the thumb of her MLR people viz-a-viz Twitter, there was someone from Boehringer-Ingelheim (BI) in the audience who did not seem afraid to live tweet. As you may know, I have had both good and bad things to say about BI's SM projects, but they are not scaredy cats -- as if my comments could scare anyone!


  1. Anonymous12:28 PM

    I've worked on both sides of the table in the above example. It comes down to a mixed message from leadership in the company. Commercial is saying "innovate". Compliance/Legal/Regulatory is saying "prevent".

  2. Anonymous12:31 PM

    I have been that pioneer at a pharma company. It's well past time that companies train their SM employees well, so they know the rules and the boundaries and trust them to do their job.

  3. Anonymous1:35 PM

    It is not limited to pharmaceutical companies. I work for a vendor to pharmaceutical companies and am subject to a similar work process, though we have no similar regulations guiding our interactions with our target audience as pharma companies do. It involves writing any online material, submitting, obtaining signatures, and waiting a week to obtain approval. Even the CEO has admitted my work and position is the only one with this degree of review and constant critique- but there has been no move to change that. People are scared of the "volume" an online voice can give a person and don't understand that the conversation will go on, with or without us.

    I think many companies do not trust their employees, regardless of the industry.

  4. John: This is an excellent post. For way too long MLR teams have stood in the way of better DTC marketing and their constant refusal to acknowledge connected consumers and lack of knowledge about social media is slowly draining the life's blood out of pharma marketers and driving them into other industries. Changes are needed but they have to come from the top and pharma marketers have to take more risks when those risks mean better patient marketing and making a difference in patients lives. Legal and regulatory people have way too much power and they wield it for their own good not for the good of patients

  5. Hard to believe, but many of the first corporate pharma sites launched before 2000 were actually created by a single person within the company! That person frequently wrote all the content without any MLR. Now, I can see where that would be a problem. But it would be much more efficient to give a trusted, well-trained person the authority to do such a simple tasks as write interactive, real-time tweets without prior review of every word. That's absurd! A blog post, on the other hand, is something that can stand the review process -- it's not time sensitive and not as interactive as Twitter. Even responding to comments on blogs could be subject to MLR without diminishing their utility. I think this situation requires compromise on both sides: PR/marketing vs. MLR People. I think PR/Mkting have simply "rolled over" and accepted all of MLR's demands. The ones forced to "roll over" are probably those whose company simply has no SM guidelines, no training, and no contingency plans -- they simply have top-down control. Marketing people should demand more, but they must push for guidelines, playbooks, and training and accept some responsibility as well when things go wrong.

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  7. Great post. I'm the social media director for a small pharma co out west. Everything needs to be pre-approved before being send. I understand the need for this, but I do think we play it too safe a lot of time.

    Social media is meant to be a conversation, not a script.


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