The UK PMCPA has released new social media guidelines

The Prescription Medicines Code of Practice Authority (PMCPA) has released new Social Media Guidance.

Established in 1993, the PMCPA is the self-regulatory body which administers the Association of the British Pharmaceutical Industry (ABPI) Code of Practice for the Pharmaceutical Industry, independently of the ABPI¹. 

With increasing use of social media globally, pharmaceutical companies may consider social media as an opportunity to engage target audiences and build brand awareness.  

However, pharmaceutical companies are strictly prohibited from promoting prescription only medicines (POMs) to the public¹. This can create a challenge for pharmaceutical companies when sharing information on social media as endorsing product is against regulations.

Therefore, the UK PMCPA released new social media guidance to support pharmaceutical companies when using social media. Especially as there is a high risk that content created by pharmaceutical companies can be easily shared and may reach the public, leading to a potential breach of the regulations.  

“In the UK, the control of medicines advertising is based on the long established system of self-regulation and is supported by the statutory role of the Medicines and Healthcare products Regulatory Agency (MHRA). The Association of the British Pharmaceutical Industry (ABPI) Code of Practice (ABPI code), administered by the Prescription Medicines Code of Practice Authority (PMCPA), is the self-regulatory system covering prescription medicines. The ABPI Code reflects and extends beyond UK law. A Memorandum of Understanding setting out the arrangements for the regulation of the promotion of medicines for prescribing was agreed between the PMCPA, the ABPI and the MHRA.”  PMPCA Social Media Guidance, 2023.

The PMCPA can only give informal advice based on its interpretation of the ABPI code¹. The ABPI Code covers the promotion of medicines for prescribing to both UK health professionals and other relevant decision makers. In addition, it sets standards for the provision of information about prescription only medicines to the public¹. 

Although the UK PMCPA social media guidance does not prohibit a pharmaceutical company from having a social media account such as a corporate account or separate accounts related to specific activities or stakeholder groups, it does inevitably mean that pharmaceutical companies should approach and review their communications, activities and materials very carefully. Caution should be taken to ensure compliance to PMCPA guidance as well as General Data Protection Regulation (GDPR) requirements¹.  

Practical considerations of the new UK PMCPA Social Media Guidance:

• Using links
  • Links must be clear and clearly state the association to the pharmaceutical company¹. 
• Tagging 
  • When directing readers to other accounts via tagging, pharmaceutical companies and their employees need to be satisfied that the content on those accounts is non-promotional¹. 
• Hashtags
  • Appropriate hashtags must be used that do not use language viewed to be promotional¹.
• Responding to misinformation/correcting inaccuracies
  • Companies can link to reference information that is non-promotional and adheres to ABPI Code¹. 
• Signposting vs posting/sharing/re-sharing
  • Pharmaceutical companies can signpost to events but must not directly or indirectly promote a POM whereas content posted/shared/re-shared by pharmaceutical companies that relates to products or diseases should be examined to confirm compliance with the ABPI Code and where applicable certified in advance¹. 
• Corporate news and announcements
  • Pharmaceutical companies can post or share news that is appropriate for the public. This may include corporate partnerships, employee recognition and company awards however the regulations do not allow information relating to topics such as products or pipeline assets¹.
• Professional profiles and job advertising
  • POMs should not be mentioned in the job specification or promotion of the vacancy¹. 
• Disease awareness for the public
  • Care must be taken not to mention the company’s product(s)¹. 
• Patient support
  • Information can be posted on social media to support patients prescribed a specific POM however content must sit in a secured section on social media. For example, this would work well in the instance of a product training video hosted on YouTube which could only be accessed via a unique URL¹.
• Meetings/advertisements
  • Social media can be used to signpost educational activities however promotional activities should not be disguised and access should be limited to the relevant group of health professionals only¹.  
• Product and pipeline milestones
  • Information must be presented in a non-promotional and factual way and if intended for investment and financial audiences, the content should emphasise the business importance of the information. This must be done very carefully as if pharmaceutical companies are sharing content on a social media platform, there is a high chance this can be reached by the wider public. Therefore, pharmaceutical companies may even consider closed groups for journalists and investors so that they can share this information between the intended audience¹.  
• Working with social media influencers
  • Working with experts in the field is common and may be required to advise on services, for content creation and for posting of digital content. However, due to their reach and potential influence on the public, transparency is essential and the relationship between the influencer or KOL must be made clear at the outset. As a third party, the individual or group must also be made aware of the appropriate law and legislation¹.
• Promotion to Health Professionals and Other Relevant Decision Makers (ORDMs)
  • When it comes to paid for promotion such as digital display advertising on social media, not only should it be clear of the pharmaceutical company’s involvement, but companies must also ensure that promotion is carefully targeted to relevant and intended groups of healthcare professionals. This can be done by utilising functionalities on social media platforms that can restrict certain content to specific groups only. Furthermore, restrictions should be put in place to ensure that prohibited content can not be actively shared with the public¹.  
• Clinical trial recruitment
  • Companies must make efforts to target only appropriate individuals that can reasonably fulfil the demographics/criteria for the trial and can be screened. Specific products should not be referred to and any adverse events reported via social media should be managed effectively as per the law and regulations in place¹. 

References

1. PMCPA. Social Media Guidance 2023 [Internet]. 2023 [cited 2023 Feb 10]. Available from: https://www.pmcpa.org.uk/media/x2pbqzy1/pmcpa-social-media-guidance-2023.pdf