Beware the Surveillance State! While the recent attention to the busted secrets of the National Security Agency may have spurred paranoia about who reads your emails and follows your Internet movements, the technology at issue warrants caution by pharma marketers.

What is possible for NSA and allied agencies is also possible for agencies like FDA who have to keep up with ever-more sophisticated, non-traditional methods and environments in cyberspace.

And, like the guardians of national security, FDA market watchers are unlikely to broadcast the nature of their surveillance programs, technologies and methods. Such secrecy is not required by law and regulations as it is in the NSA model, but it is a byproduct of a culture of nondisclosure.

What do pharma ­marketers need to be mindful of as the Surveillance State equips agencies like FDA to monitor what you’re doing?

As in the NSA model, FDA will be able to “aggregate” marketing activities down to individual contacts online, store them in the cloud, monitor suspicious patterns, connect the dots and zero in with greater speed and accuracy than ever before.

The days when FDA had to wait for a competitor to bring evidence of violative promotional claims are disappearing. This is beginning to release the talents and energies of the 70-person Office of Prescription Drug Promotion for more efficient—and effective—projection of its educational and enforcement efforts.

Industry’s awareness of this may be a reason why it has been slow to commit to cyberspace marketing. But marketing in cyberspace is fast becoming the norm—and the industry needs to adapt.


James G. Dickinson is editor of Dickinson’s FDA Webview (fdaweb.com).