Social media rules for pharmas

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At a recent conference, I told two perplexed-looking FDA attendees that I thought pharma has a distinct advantage with social media, because we're used to marketing with boundaries, and social-media rules and FDA guidelines are actually quite similar. Those of us who live in social media don't tolerate companies that promote covertly, make inaccurate claims or try to bury their mistakes or product limitations. The consumer packaged goods, travel and entertainment industries are not adjusting as well to these unwritten social media rules. 

Here are some rules for reaching consumers via social media. Only your lawyer and PR team can decide if it's right for you.

1. If you don't have a social-media policy, write one. Guidelines clarify an employee's obligations, but more importantly, identify which department owns the channel. Personally, I think it's a collaborative decision, and those aren't easy. Because social media usually refers to "earned" media, it's natural for PR to clarify nuances, monitor conversations and engage selectively. Without clear policies, we'll see well-intentioned marketers make embarrassing mistakes (i.e, editing competitors' Wikipedia pages, not realizing their IP tracks them to their employer). We'll also see manufacturers falling dangerously behind consumer hype. In 1999, I knew product directors who didn't want a website because the Internet was packed with lies!

2. Unbranded advertising works quite well in social media. It's less self-serving, and equally effective unless you're the 12th statin to market. I've seen great results allowing publishers to manage social media to aggregate target consumers, where the marketer had no role except to run unbranded ads. The conversion sometimes beat paid search, otherwise the most cost-efficient means. 

3. Speed up review time. Social media is built for sound bites, and our approval machines are made for reviewing enormous and complex promotional materials over the course of months. By the time the machine spits out the approved copy, the issue will have resolved without us and the opportunity to engage missed.

4. We have a new way to reach large audiences. I consult with Hitviews, a company that connects brands to "web stars" and their enormous audiences. We recently did a program that gave Fox Broadcasting an incredible ROI by having dozens of web-video stars talking about two TV shows (for pennies per view). The platform could work for a differentiated Rx brand looking to increase treatment and diagnosis rates in large, important therapeutic areas (unbranded of course, but it could drive to branded content). 

5. Have a "badged physician" (identified by the company) pay monthly visits to Wikipedia entries for their products, and in the "discussion" tab post polite comments where there are inaccuracies or omissions. Keep comments terse and link to the source. Simple, safe, and vital considering how highly Wikipedia pages place on search engines. There are companies that will do this for you, though sometimes with physicians not disclosing their biases. 
When the chaos and fears subside, I believe the transparency of social media will give manufacturers the chance to emerge again as collections of honest people determined to help patients and providers.

Kevin Nalty is a former Merck marketer, social media consultant ( and a top producer of comical YouTube videos, with 80 million views to date

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