Regulatory authorities have been working on social media guidelines for drug and device marketers for some time. These were due to be delivered at various times, most recently, by the end of the first quarter of 2011. Yet here we are, entering a new year, and the reality is that we may never receive explicit guidance from regulatory authorities on the use of social media.
To be fair, the rapidly shifting social media landscape makes it difficult – if not impossible – for regulatory bodies to produce meaningful guidelines that have any shelf life at all. Yet we are not flying entirely blind. While it is impossible to cover every situation and scenario in the incredibly dynamic space that IS social media, the aim of this article is to provide a sense of the types of questions pharmaceutical executives should be asking about what can and cannot be done with social media.
Social Media Defined
Step 1 is to agree on a definition for ‘social media.’ This is not easy because nearly everyone has an opinion about what the term means. The precise definition of ‘social media’ is not critical, but the key concept to bear in mind is this: ‘Social media’ does not refer to any individual site, such as Facebook or Twitter. Rather, it refers to any online media outlet, application or tool that allows people to collaborate and share information. Importantly, regulators have embraced this wider view of social media.
In general, social media sites encourage people to upload a profile containing information about themselves and allow users to share that information online with others. Social media encompasses a wide range of categories, including but not limited to, the following:
- Social Networking – e.g., Facebook, Twitter, Badoo, QQ, LinkedIn
- Social Bookmarking Sites – e.g., Delicious, Stumbleupon
- Social News Sites – e.g., Digg, Reddit
- Community Forums – e.g., CafePharma, qsrhelp.com, MDTF
- Social Wikis – e.g., Wikipedia, Intellipedia
- Blogging Sites – e.g., Blogspot, Blogster
Regulators care about what is being shared and where it can go once it leaves the creator’s fingertips. It’s about what you post AND where it ends up, geographically or demographically.
Why Social Media? ...