Social media checklist for pharmaceutical companies

Following the latest release of the Prescription Medicines Code of Practice Authority (PMPCA) Social Media Guidance 2023 outlining the law and regulation on the use of social media by pharmaceutical companies, HRS have created a checklist for pharmaceutical companies considering setting up a social media account or reviewing their current policy.

If you haven’t read the PMPCA Social Media Guidance yet, check out our summary of the full report here.

HRS’ social media checklist for pharmaceutical companies to ensure content is compliant:

• Are all company employees aware and sufficiently trained on the relevant terms and conditions for social media channels and GDPR requirements? This includes both professional and personal use of social media so as to avoid overlap with professional responsibilities and to mitigate the risk of content being shared with contacts outside of their company network.
• Are all company employees aware of the Advertising Standards Authority UK Code of Non-broadcast Advertising and Direct & Promotional Marketing (CAP Code)?
• Are clear procedures in place outlining who will be responsible for monitoring the account, activities, content and materials shared on social media?
• Do you have a protocol in place to manage any reported adverse events on social media?
• If inappropriate comments arise, do you have a person or agency that can monitor, moderate and/or delete those comments in a timely manner?
• Have you created an internal social media guidelines which sets the expectation and boundaries to clarify what behaviour is expected online?
• As it is the responsibility of the pharmaceutical company to ensure that all of the people that work for them are responsible for material disseminated/activities carried out on social media, how will you ensure anyone new to the company or third parties (including contracted speakers/influencers) will be regularly trained on company’s social media guidance? This includes:
  • Relevant ABPI Code requirements
  • Relevant company policies & procedures
  • Ownership and control including use of and potential withdrawal of materials both during and after the contracted period
• Do you have a process in place to review social media content from your contracted parties?

The guidance also outlines questions to ask internally prior to circulating any social media content. These include questions such as¹:

• “What is the objective of the activity?”
• “Who is the audience (for example, public, health professionals, media, investors) and is the content suitable and appropriately signposted for that audience?”
• “Is the role of the pharmaceutical company clear?”

A list of these questions can be found in the full report here.

References

1. PMCPA. Social Media Guidance 2023 [Internet]. 2023 [cited 2023 Feb 16]. Available from: https://www.pmcpa.org.uk/media/x2pbqzy1/pmcpa-social-media-guidance-2023.pdf